ML18065A529: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(Created page by program invented by StriderTol)
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 27, 2018 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO) Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555  
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 27, 2018 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)
Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555


==SUBJECT:==
==SUBJECT:==
BRAIDWOOD STATION, UNITS 1 AND 2, AND BYRON STATION, UNIT NOS. 1 AND 2-ISSUANCE OF AMENDMENTS REGARDING CLARIFICATION OF ROD POSITION REQUIREMENTS (CAC NOS. MF9951, MF9952, MF9953, AND MF9954; EPID L-2017-LLA-0249)  
BRAIDWOOD STATION, UNITS 1 AND 2, AND BYRON STATION, UNIT NOS.
1 AND 2- ISSUANCE OF AMENDMENTS REGARDING CLARIFICATION OF ROD POSITION REQUIREMENTS (CAC NOS. MF9951, MF9952, MF9953, AND MF9954; EPID L-2017-LLA-0249)


==Dear Mr. Hanson:==
==Dear Mr. Hanson:==
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 196 to Renewed Facility Operating License No. NPF-72 and Amendment No. 196 to Renewed Facility Operating License No. NPF-77 for the Braidwood Station, Units 1 and 2, respectively, and Amendment No. 202 to Renewed Facility Operating License No. NPF-37 and Amendment No. 202 to Renewed Facility Operating License No. NPF-66 for the Byron Station, Unit Nos. 1 and 2, respectively.
 
The amendments are in response to your application dated June 30, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17187A191 ), as supplemented by letters dated October 25, 2017 (ADAMS Accession No. ML172986536) and May 29, 2018 (ADAMS Accession No. ML18149A637}.
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 196 to Renewed Facility Operating License No. NPF-72 and Amendment No.
B. Hanson A copy of the related Safety Evaluation is also enclosed.
196 to Renewed Facility Operating License No. NPF-77 for the Braidwood Station, Units 1 and 2, respectively, and Amendment No. 202 to Renewed Facility Operating License No. NPF-37 and Amendment No. 202 to Renewed Facility Operating License No. NPF-66 for the Byron Station, Unit Nos. 1 and 2, respectively. The amendments are in response to your application dated June 30, 2017 (Agencywide Documents Access and Management System (ADAMS)
The Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Docket Nos. STN 50-456, STN 50-457, STN 50-454, and STN 50-455  
Accession No. ML17187A191 ), as supplemented by letters dated October 25, 2017 (ADAMS Accession No. ML172986536) and May 29, 2018 (ADAMS Accession No. ML18149A637}.
 
B. Hanson                                     A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
                                              ~~:1-Joel S. Wiebe, Senior Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454, and STN 50-455


==Enclosures:==
==Enclosures:==
: 1. Amendment No. 196 to NPF-72 2. Amendment No. 196 to NPF-77 3. Amendment No. 202 to NPF-37 4. Amendment No. 202 to NPF-66 5. Safety Evaluation cc w/enclosures:
: 1. Amendment No. 196 to   NPF-72
Listserv Sincerely, ~~:1-Joel S. Wiebe, Senior Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-456 BRAIDWOOD STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 196 Renewed License No. NPF-72 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 30, 2017, as supplemented by letters dated October 25, 2017 and May 29, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
: 2. Amendment No. 196 to   NPF-77
: 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2} of Renewed Facility Operating License No. NPF-72 is hereby amended to read as follows: Enclosure 1
: 3. Amendment No. 202 to   NPF-37
(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 196 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. 3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance.  
: 4. Amendment No. 202 to   NPF-66
: 5. Safety Evaluation cc w/enclosures: Listserv
 
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-456 BRAIDWOOD STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 196 Renewed License No. NPF-72
: 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.     The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 30, 2017, as supplemented by letters dated October 25, 2017 and May 29, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.     The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.     There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.     The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.     The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
: 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2} of Renewed Facility Operating License No. NPF-72 is hereby amended to read as follows:
Enclosure 1
 
(2)   Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 196 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
: 3.       This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
()J          9 cf~
David J. Wrona, Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation


==Attachment:==
==Attachment:==
Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance:      June 2 7 ,  2 O1 8
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-457 BRAIDWOOD STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 196 Renewed License No. NPF-77
: 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.      The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 30, 2017, as supplemented by letters dated October 25, 2017 and May 29, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;
: 8.      The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.      There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.      The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.      The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
: 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-77 is hereby amended to read as follows:
Enclosure 2


Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance:
(2)   Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 196 and the Environmental Protection Plan contained in Appendix B, both of which are attached to Renewed License No. NPF-72, dated January 27, 2016, are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
June 2 7 , 2 O 1 8 FOR THE NUCLEAR REGULATORY COMMISSION
: 3.     This license amendment is effective as of the date if its issuance and shall be implemented within 60 days of the date of issuance.
()J 9 cf~ David J. Wrona, Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-457 BRAIDWOOD STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 196 Renewed License No. NPF-77 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 30, 2017, as supplemented by letters dated October 25, 2017 and May 29, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; 8. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
FOR THE NUCLEAR REGULATORY COMMISSION
: 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-77 is hereby amended to read as follows: Enclosure 2
()JO<\(_
(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 196 and the Environmental Protection Plan contained in Appendix B, both of which are attached to Renewed License No. NPF-72, dated January 27, 2016, are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. 3. This license amendment is effective as of the date if its issuance and shall be implemented within 60 days of the date of issuance.  
David J. Wron/~hief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation


==Attachment:==
==Attachment:==
Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: June 2 7 , 2 O1 8
ATTACHMENT TO LICENSE AMENDMENT NOS. 196 AND 196 RENEWED FACILITY OPERATING LICENSE NOS. NPF-72 AND NPF-77 BRAIDWOOD STATION, UNITS 1 AND 2 DOCKET NOS. STN 50-456 AND STN 50-457 Replace the following pages of the Renewed Facility Operating Licenses and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove License NPF-72                      License NPF-72 Page 3                              Page 3 License NPF-77                      License NPF-77 Page 3                              Page 3 TSs                                TSs 3.1.4-4                            3.1.4-4 3.1.5-1                            3.1.5-1 3.1.5-2                            3.1.5-2 3.1.6-1                            3.1.6-1 3.1.6-2                            3.1.6-2 3.1.6-3                            3.1.6-3 3.1.7-1                            3.1.7-1 3.1.7-2                            3.1.7-2 3.1.7-3 3.1.7-4
(2)    Exelon Generation Company, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (3)    Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)    Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)    Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
( 1)    Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of 3645 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.
(2)    Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 196 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
Renewed License No. NPF-72 Amendment No. 196


Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance:
(2)     Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (3)     Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)     Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)     Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
June 2 7 , 2 O 1 8 FOR THE NUCLEAR REGULATORY COMMISSION
C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
()JO<\(_ David J. Wron/~hief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation ATTACHMENT TO LICENSE AMENDMENT NOS. 196 AND 196 RENEWED FACILITY OPERATING LICENSE NOS. NPF-72 AND NPF-77 BRAIDWOOD STATION, UNITS 1 AND 2 DOCKET NOS. STN 50-456 AND STN 50-457 Replace the following pages of the Renewed Facility Operating Licenses and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Remove License NPF-72 Page 3 License NPF-77 Page 3 TSs 3.1.4-4 3.1.5-1 3.1.5-2 3.1.6-1 3.1.6-2 3.1.6-3 3.1.7-1 3.1.7-2 License NPF-72 Page 3 License NPF-77 Page 3 TSs 3.1.4-4 3.1.5-1 3.1.5-2 3.1.6-1 3.1.6-2 3.1.6-3 3.1.7-1 3.1.7-2 3.1.7-3 3.1.7-4  (2) Exelon Generation Company, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (3) Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
(1)     Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of 3645 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.
C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: ( 1) (2) Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of 3645 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein. Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 196 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. Renewed License No. NPF-72 Amendment No. 196  (2) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (3) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
(2)    Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 196 and the Environmental Protection Plan contained in Appendix B, both of which are attached to Renewed License No. NPF-72, dated January 27, 2016, are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: (1) Maximum Power Level (2) The licensee is authorized to operate the facility at reactor core power levels not in excess of 3645 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein. Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 196 and the Environmental Protection Plan contained in Appendix B, both of which are attached to Renewed License No. NPF-72, dated January 27, 2016, are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. Renewed License No. NPF-77 Amendment No. 196 Rod Group Alignment Limits 3.1.4 ACTIONS (continued)
Renewed License No. NPF-77 Amendment No. 196
CONDITION REQUIRED ACTION D. Required Action and D.1 Be in MODE 3. associated Completion Time of Condition B or Required Action C.3 not met. SURVEILLANCE REQUIREMENTS SR 3.1.4.1 SR 3.1.4.2 SR 3.1.4.3 SURVEILLANCE
 
-------------------NOTE--------------------
Rod Group Alignment Limits 3.1.4 ACTIONS (continued)
CONDITION                       REQUIRED ACTION           COMPLETION TIME D. Required Action and         D.1       Be in MODE 3.           6 hours associated Completion Time of Condition B or Required Action C.3 not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                FREQUENCY SR 3.1.4.1     -------------------NOTE--------------------
Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.
Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.
Verify pQsition of individual rods within al i gnment l i mi t. Verify rod freedom of movement (trippability) by moving each rod not fully inserted in the core~ 10 steps in either direction.
Verify pQsition of individual rods within           In accordance al i gnment l i mi t.                               with the Surveillance Frequency Control Program SR 3.1.4.2      Verify rod freedom of movement                       In accordance (trippability) by moving each rod not fully         with the inserted in the core~ 10 steps in either             Surveillance direction.                                           Frequency Control Program SR 3.1.4.3      Verify rod drop time of each rod, from the           Prior to fully withdrawn position, is~ 2.7 seconds           criticality from the beginning of decay of stationary           after each gripper coil voltage to dashpot entry,               removal of the with:                                                reactor head
Verify rod drop time of each rod, from the fully withdrawn position, is~ 2.7 seconds from the beginning of decay of stationary gripper coil voltage to dashpot entry, with: a. Tavg 550&deg;F; and b. All reactor coolant pumps operating.
: a. Tavg ~ 550&deg;F; and
BRAIDWOOD  
: b. All reactor coolant pumps operating.
-UNITS 1 & 2 3.1.4 -4 COMPLETION TIME 6 hours FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Prior to criticality after each removal of the reactor head Amendment 196 Shutdown Bank Insertion Limits 3.1.5 3.1 REACTIVITY CONTROL SYSTEMS 3.1.5 Shutdown Bank Insertion Limits LCD 3.1. 5 Each shutdown bank shall be within the insertion limits specified in the COLR. ----------------------------NOTE----------------------------
BRAIDWOOD - UNITS 1 &2                   3.1.4 - 4                   Amendment   196
Not applicable to shutdown banks inserted while performing SR 3.1.4.2. APPLICABILITY:
 
MODES 1 and 2. ACTIONS CONDITION A. One shutdown bank inserted~
Shutdown Bank Insertion Limits 3.1.5 3.1 REACTIVITY CONTROL SYSTEMS 3.1.5 Shutdown Bank Insertion Limits LCD 3.1. 5       Each shutdown bank shall be within the insertion limits specified in the COLR.
16 steps beyond the insertion limits specified in the COLR. BRAIDWOOD
                  ----------------------------NOTE----------------------------
-UNITS 1 & 2 A.l AND REQUIRED ACTION COMPLETION TIME Verify all control 1 hour banks are within the insertion limits specified in the COLR. A. 2 .1 Verify SOM is within 1 hour the limits specified in the COLR. OR A.2.2 Initiate boration to 1 hour restore SOM to within limit. A. 3 Restore the shutdown 24 hours bank to within the insertion limits specified in the COLR. (continued) 3.1.5-1 Amendment 196 Shutdown Bank Insertion Limits 3.1.5 ACTIONS (continued)
Not applicable to shutdown banks inserted while performing SR 3.1.4.2.
CONDITION REQU I RED ACTION B. One or more shutdown B.1.1 Verify SDM is within banks not within the limits specified limits for reasons in the COLR. other than Condition A. OR B.1.2 Initiate boration to restore SDM to within 1 imi t. AND B.2 Restore shutdown bank(s) to within 1 imits. C. Required Action and C.l Be in MODE 3. associated Completion Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.1.5.1 Verify each shutdown bank is within the insertion limits specified in the COLR. BRAIDWOOD  
APPLICABILITY:   MODES 1 and 2.
-UNITS 1 & 2 3.1.5-2 COMPLETION TIME 1 hour 1 hour 2 hours 6 hours FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment 196 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 Control Bank Insertion Limits Control Bank Insertion Limits 3.1.6 LCD 3.1.6 Each control bank shall be within the insertion, sequence, and overlap limits specified in the COLR. ----------------------------NOTE----------------------------
ACTIONS CONDITION                   REQUIRED ACTION          COMPLETION TIME A. One shutdown bank         A.l     Verify all control     1 hour inserted~ 16 steps                banks are within the beyond the insertion               insertion limits limits specified in                specified in the the COLR.                         COLR.
Not applicable to control banks inserted while performing SR 3.1.4.2. APPLICABILITY:
AND A. 2.1   Verify SOM is within   1 hour the limits specified in the COLR.
MODE 1, MODE 2 with keff 1. 0. ACTIONS CONDITION A. Control bank A, B or C A.l. inserted~
OR A.2.2   Initiate boration to   1 hour restore SOM to within limit.
16 steps beyond the insertion, sequence, or overlap limits specified in the COLR. AND REQUIRED ACTION COMPLETION TIME Verify all shutdown 1 hour banks are within the insertion limits specified in the COLR. A.2.1 Verify SOM is within 1 hour BRAIDWOOD
A. 3     Restore the shutdown   24 hours bank to within the insertion limits specified in the COLR.
-UNITS 1 & 2 the limits specified in the COLR. A.2.2 Initiate boration to 1 hour AND A.3 restore SOM to within limit. Restore the control bank to within the insertion, sequence, and overlap limits specified in the COLR. 3.1.6-1 24 hours (continued)
(continued)
Amendment 196 ACTIONS (continued)
BRAIDWOOD - UNITS 1 &2                3.1.5-1                       Amendment   196
CONDITION B. Control bank insertion limits not met for reasons other than Condition A. C. Control bank sequence or overlap limits not met for reasons other than Condition A. D. Required Action and associated Completion Time not met. BRAIDWOOD  
 
-UNITS 1 & 2 B.1.1 OR B.1.2 AND B.2 C.1.1 OR C.1.2 AND C.2 D.l Control Bank Insertion Limits 3.1.6 REQUIRED ACTION COMPLETION TIME Verify SDM i's within 1 hour the limits specified in the COLR. Initiate boration to 1 hour restore SDM to within limit. Restore control 2 hours bank(s) to within limits. Verify SDM is within 1 hour the limits specified in the COLR. Initiate boration to 1 hour restore SDM to within limit. Restore control bank 2 hours sequence and overlap to within limits. Be in MODE 2 with 6 hours kett < 1.0. 3.1.6 -2 Amendment 196 Control Bank Insertion Limits 3.1.6 SURVEILLANCE REQUIREMENTS SR 3.1.6.1 SR 3.1.6.2 SR 3.1.6.3 SURVEILLANCE Verify estimated critical control bank position is within the limits specified in the COLR. Verify each control bank is within the insertion limits specified in the COLR. Verify each control bank not fully withdrawn from the core is within the sequence and overlap limits specified in the COLR. BRAIDWOOD  
Shutdown Bank Insertion Limits 3.1.5 ACTIONS (continued)
-UNITS 1 & 2 3.1.6-3 FREQUENCY Within 4 hours prior to criticality In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment 196 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Rod Position Indication Rod Position Indication 3.1. 7 LCO 3.1.7 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.
CONDITION                   REQU I RED ACTION         COMPLETION TIME B. One or more shutdown       B.1.1   Verify SDM is within     1 hour banks not within                   the limits specified limits for reasons                 in the COLR.
APPLICABILITY:
other than Condition A.                 OR B.1.2   Initiate boration to     1 hour restore SDM to within 1imi t.
MODES 1 and 2. ACTIONS -------------------------------------NOTE-------------------------------------
AND B.2     Restore shutdown         2 hours bank(s) to within 1imits.
C. Required Action and       C.l     Be in MODE 3.           6 hours associated Completion Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                               FREQUENCY SR 3.1.5.1     Verify each shutdown bank is within the           In accordance insertion limits specified in the COLR.         with the Surveillance Frequency Control Program BRAIDWOOD - UNITS 1 &2               3.1.5-2                         Amendment  196
 
Control Bank Insertion Limits 3.1.6 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 Control Bank Insertion Limits LCD 3.1.6         Each control bank shall be within the insertion, sequence, and overlap limits specified in the COLR.
                  ----------------------------NOTE----------------------------
Not applicable to control banks inserted while performing SR 3.1.4.2.
APPLICABILITY:   MODE 1, MODE 2 with keff ~ 1. 0.
ACTIONS CONDITION                     REQUIRED ACTION          COMPLETION TIME A. Control bank A, B or C A.l.         Verify all shutdown    1 hour inserted~ 16 steps                 banks are within the beyond the insertion,               insertion limits sequence, or overlap               specified in the limits specified in                 COLR.
the COLR.
AND A.2.1     Verify SOM is within   1 hour the limits specified in the COLR.
A.2.2     Initiate boration to   1 hour restore SOM to within limit.
AND A.3        Restore the control   24 hours bank to within the insertion, sequence, and overlap limits specified in the COLR.
(continued)
BRAIDWOOD - UNITS 1 &2               3.1.6-1                         Amendment  196
 
Control Bank Insertion Limits 3.1.6 ACTIONS (continued)
CONDITION                REQUIRED ACTION           COMPLETION TIME B. Control bank insertion B.1.1    Verify SDM i's within   1 hour limits not met for            the limits specified reasons other than            in the COLR.
Condition A.
OR B.1.2    Initiate boration to     1 hour restore SDM to within limit.
AND B.2      Restore control         2 hours bank(s) to within limits.
C. Control bank sequence  C.1.1    Verify SDM is within     1 hour or overlap limits not          the limits specified met for reasons other          in the COLR.
than Condition A.
OR C.1.2    Initiate boration to   1 hour restore SDM to within limit.
AND C.2      Restore control bank     2 hours sequence and overlap to within limits.
D. Required Action and  D.l      Be in MODE 2 with       6 hours associated Completion          kett < 1.0.
Time not met.
BRAIDWOOD - UNITS 1 &2          3.1.6 - 2                       Amendment   196
 
Control Bank Insertion Limits 3.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE                            FREQUENCY SR 3.1.6.1     Verify estimated critical control bank       Within 4 hours position is within the limits specified in   prior to the COLR.                                     criticality SR 3.1.6.2    Verify each control bank is within the       In accordance insertion limits specified in the COLR.       with the Surveillance Frequency Control Program SR 3.1.6.3    Verify each control bank not fully           In accordance withdrawn from the core is within the        with the sequence and overlap limits specified in     Surveillance the COLR.                                     Frequency Control Program BRAIDWOOD - UNITS 1 &2             3.1.6-3                       Amendment 196
 
Rod Position Indication 3.1. 7 3.1  REACTIVITY CONTROL SYSTEMS 3.1.7 Rod Position Indication LCO 3.1.7         The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.
APPLICABILITY:   MODES 1 and 2.
ACTIONS
-------------------------------------NOTE-------------------------------------
Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.
Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.
CONDITION A. One DRPI per group inoperable in one or more groups. BRAIDWOOD
CONDITION                   REQUIRED ACTION          COMPLETION TIME A. One DRPI per group         A.l     Verify the position     Once per  8  hours inoperable in one or              of the rods with more groups.                      inoperable DRPis.
-UNITS 1 & 2 A.l OR A.2 REQUIRED ACTION Verify the position of the rods with inoperable DRPis. Verify the position of the rods with inoperable DRPis. 3.1.7-1 COMPLETION TIME Once per 8 hours 8 hours AND Once per 31 EFPD thereafter 8 hours after discovery of each unintended rod movement (continued)
OR A.2    Verify the position     8 hours of the rods with inoperable DRPis.       AND Once per 31 EFPD thereafter 8 hours after discovery of each unintended rod movement (continued)
Amendment 196 CONDITION A. (continued)
BRAIDWOOD - UNITS 1 &2              3.1.7-1                   Amendment    196
OR A.3 B. More than one DRPI per B.1 group inoperable in one or more groups. AND B.2 BRAIDWOOD
 
-UNITS 1 & 2 Rod Position Indication 3.1. 7 REQUIRED ACTION COMPLETION TIME 8 hours after each movement of rod with inoperable DRPI > 12 steps AND Prior to THERMAL POWER exceeding 50% RTP AND 8 hours after reaching RTP Reduce THERMAL POWER 8 hours TO 50% RTP. Place the control Imnediately rods under manual control. Restore inoperable 24 Hours DRPis to OPERABLE status such that a maximum of one DRPI per grou~ is inoperab e. (continued) 3.1.7-2 Amendment 196 ACTIONS (continued)
Rod Position Indication 3.1. 7 CONDITION              REQUIRED ACTION           COMPLETION TIME A.  (continued)                                        8 hours after each movement of rod with inoperable DRPI
CONDITION C. One or more DRPis inoperable in one or more groups and associated rod has been moved> 24 steps in one direction since the last determination of the rod's position.
                                                        > 12 steps AND Prior to THERMAL POWER exceeding 50% RTP AND 8 hours after reaching RTP OR A.3  Reduce THERMAL POWER   8 hours TO ~ 50% RTP.
D. One or more demand position indicators per bank inoperable in one or more banks. E. Required Action and associated Completion Time not met. BRAIDWOOD
B. More than one DRPI per B.1  Place the control       Imnediately group inoperable in        rods under manual one or more groups.        control.
-UNITS 1 & 2 C.l OR C.2 0.1.1 AND 0.1.2 OR 0.2 E.l Rod Position Indication 3.1. 7 REQUIRED ACTION COMPLETION TIME Initiate action to Inmediately verify the position of the rods with inoperable DRPis. Reduce THERMAL POWER 8 hours to s 50% RTP. Verify by Once per 8 hours administrative means all DRPis for the affected bank(s) are OPERABLE.
AND B.2  Restore inoperable     24 Hours DRPis to OPERABLE status such that a maximum of one DRPI per grou~ is inoperab e.
Verify the most Once per 8 hours withdrawn rod and the least withdrawn rod of the affected bank(s) are s 12 steps apart. Reduce THERMAL POWER 8 hours to s 50% RTP. Be in MODE 3. 6 hours 3.1.7-3
(continued)
* Amendment 196 Rod Position Indication 3.1. 7 SURVEILLANCE REQUIREMENTS SR 3.1.7.1 SURVEILLANCE
BRAIDWOOD - UNITS 1 &2        3.1.7-2                 Amendment   196
-------------------NOTE--------------------
 
Not required to be met for DRPis associated with rods that do not meet LCD 3.1.4. Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel. BRAIDWOOD  
Rod Position Indication 3.1. 7 ACTIONS (continued)
-UNITS 1 & 2 3.1.7-4 FREQUENCY Prior to criticality after each removal of the reactor head Amendment 196 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-454 BYRON STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 202 Renewed License No. NPF-37 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 30, 2017, as supplemented by letters dated October 25, 2017 and May 29, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
CONDITION                 REQUIRED ACTION          COMPLETION TIME C. One or more DRPis       C.l      Initiate action to      Inmediately inoperable in one or           verify the position more groups and                 of the rods with associated rod has             inoperable DRPis.
: 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-37 is hereby amended to read as follows: Enclosure 3   (2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 202 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. 3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance.  
been moved> 24 steps in one direction since OR the last determination of the rod's position. C.2     Reduce THERMAL POWER   8 hours to s 50% RTP.
D. One or more demand      0.1.1    Verify by               Once per 8 hours position indicators            administrative means per bank inoperable            all DRPis for the in one or more banks.          affected bank(s) are OPERABLE.
AND 0.1.2    Verify the most         Once per 8 hours withdrawn rod and the least withdrawn rod of the affected bank(s) are s 12 steps apart.
OR 0.2      Reduce THERMAL POWER   8 hours to s 50% RTP.
E. Required Action and  E.l      Be in MODE 3.           6 hours associated Completion Time not met.
BRAIDWOOD - UNITS 1 &2            3.1.7-3
* Amendment 196
 
Rod Position Indication 3.1. 7 SURVEILLANCE REQUIREMENTS SURVEILLANCE                            FREQUENCY SR 3.1.7.1     -------------------NOTE-------------------- Prior to Not required to be met for DRPis associated criticality with rods that do not meet LCD 3.1.4.       after each removal of the reactor head Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel.
BRAIDWOOD - UNITS 1 &2             3.1.7-4                 Amendment   196
 
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-454 BYRON STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 202 Renewed License No. NPF-37
: 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.     The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 30, 2017, as supplemented by letters dated October 25, 2017 and May 29, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.     The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.     There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.     The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.     The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
: 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-37 is hereby amended to read as follows:
Enclosure 3
 
(2)   Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 202 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
: 3.     This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION C)__j,  1 0    4-J'~
David J. Wronl.Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation


==Attachment:==
==Attachment:==
Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance:    June 2 7,    2 O1 8


Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance:
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-455 BYRON STATION, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 202 Renewed License No. NPF-66
June 2 7, 2 O 1 8 FOR THE NUCLEAR REGULATORY COMMISSION C)__j, 0 4-J'~ David 1 J. Wronl. Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-455 BYRON STATION, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 202 Renewed License No. NPF-66 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 30, 2017, as supplemented by letters dated October 25, 2017 and May 29, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 1 O CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
: 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
: 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-66 is hereby amended to read as follows: Enclosure 4   (2) Technical Specifications The Technical Specifications contained in Appendix A (NUREG-1113), as revised through Amendment No. 202 and the Environmental Protection Plan contained in Appendix B, both of which were attached to Renewed License No. NPF-37, dated November 19, 2015, are hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. 3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance.  
A.     The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 30, 2017, as supplemented by letters dated October 25, 2017 and May 29, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 1O CFR Chapter I; B.     The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.     There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.     The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.     The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
: 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-66 is hereby amended to read as follows:
Enclosure 4
 
(2)   Technical Specifications The Technical Specifications contained in Appendix A (NUREG-1113), as revised through Amendment No. 202 and the Environmental Protection Plan contained in Appendix B, both of which were attached to Renewed License No. NPF-37, dated November 19, 2015, are hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
: 3.     This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
()~; q              !Y'~
David J. Wrona, Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation


==Attachment:==
==Attachment:==
Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance:    June 2 7,    2 O1 8
ATTACHMENT TO LICENSE AMENDMENT NOS. 202 AND 202 RENEWED FACILITY OPERATING LICENSE NOS. NPF-37 AND NPF-66 BYRON STATION, UNIT NOS. 1 AND 2 DOCKET NOS. STN 50-454 AND STN 50-455 Replace the following pages of the Renewed Facility Operating Licenses and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove                              Insert License NPF-37                      License NPF-37 Page 3                              Page 3 License NPF-66                      License NPF-66 Page 3                              Page 3 TSs                                TSs 3.1.4-4                            3.1.4-4 3.1.5-1                              3.1.5-1 3.1.5-2                              3.1.5-2 3.1.6-1                              3.1.6-1 3.1.6-2                              3.1.6-2 3.1.6-3                              3.1.6-3 3.1.7-1                              3.1.7-1 3.1.7-2                              3.1.7-2 3.1.7-3 3.1.7-4
(2)    Pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report, as supplemented and amended; (3)    Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)    Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)    Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
( 1)    Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of 3645 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.
(2)    Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 202 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)    Deleted.
(4)    Deleted.
Renewed License No. NPF-37 Amendment No. 202
(2)    Pursuant to the Act and 1O CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report, as supplemented and amended; (3)    Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)    Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)    Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C. The renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
( 1)    Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of 3645 megawatts thermal ( 100 percent rated power) in accordance with the conditions specified herein.
(2)    Technical Specifications The Technical Specifications contained in Appendix A (NUREG-1113), as revised through Amendment No. 202 and the Environmental Protection Plan contained in Appendix B, both of which were attached to Renewed License No. NPF-37, dated November 19, 2015, are hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
Renewed License No. NPF-66 Amendment No. 202


Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance:
Rod Group Alignment Limits 3.1.4 ACTIONS (continued)
June 2 7, 2 O 1 8 FOR THE NUCLEAR REGULATORY COMMISSION
CONDITION                     REQUIRED ACTION           COMPLETION TIME D. Required Action and         D.l     Be in MODE 3.           6 hours associated Completion Time of Condition B or Required Action C.3 not met.
()~; q !Y'~ David J. Wrona, Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation ATTACHMENT TO LICENSE AMENDMENT NOS. 202 AND 202 RENEWED FACILITY OPERATING LICENSE NOS. NPF-37 AND NPF-66 BYRON STATION, UNIT NOS. 1 AND 2 DOCKET NOS. STN 50-454 AND STN 50-455 Replace the following pages of the Renewed Facility Operating Licenses and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Remove License NPF-37 Page 3 License NPF-66 Page 3 TSs 3.1.4-4 3.1.5-1 3.1.5-2 3.1.6-1 3.1.6-2 3.1.6-3 3.1.7-1 3.1.7-2 Insert License NPF-37 Page 3 License NPF-66 Page 3 TSs 3.1.4-4 3.1.5-1 3.1.5-2 3.1.6-1 3.1.6-2 3.1.6-3 3.1.7-1 3.1.7-2 3.1.7-3 3.1.7-4  (2) Pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report, as supplemented and amended; (3) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                              FREQUENCY SR 3.1.4.1     -------------------NOTE--------------------
C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: ( 1) Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of 3645 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein. (2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 202 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. (3) Deleted. ( 4) Deleted. Renewed License No. NPF-37 Amendment No. 202  (2) Pursuant to the Act and 1 O CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report, as supplemented and amended; (3) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C. The renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: ( 1) Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of 3645 megawatts thermal ( 100 percent rated power) in accordance with the conditions specified herein. (2) Technical Specifications The Technical Specifications contained in Appendix A (NUREG-1113), as revised through Amendment No. 202 and the Environmental Protection Plan contained in Appendix B, both of which were attached to Renewed License No. NPF-37, dated November 19, 2015, are hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. Renewed License No. NPF-66 Amendment No. 202 Rod Group Alignment Limits 3.1.4 ACTIONS (continued)
CONDITION REQUIRED ACTION D. Required Action and D.l Be in MODE 3. associated Completion Time of Condition B or Required Action C.3 not met. SURVEILLANCE REQUIREMENTS SR 3.1.4.1 SR 3.1.4.2 SR 3.1.4.3 SURVEILLANCE
-------------------NOTE--------------------
Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.
Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.
Verify position of individual rods within alignment limit. Verify rod freedom of movement (trippability) by moving each rod not fully inserted in the core~ 10 steps in either direction.
Verify position of individual rods within         In accordance alignment limit.                                 with the Surveillance Frequency Control Program SR 3.1.4.2      Verify rod freedom of movement                     In accordance (trippability) by moving each rod not fully       with the inserted in the core~ 10 steps in either         Surveillance direction.                                         Frequency Control Program SR 3.1.4.3      Verify rod drop time of each rod, from the         Prior to fully withdrawn position, is~ 2.7 seconds         criticality from the beginning of decay of stationary         after each gripper coil voltage to dashpot entry,             removal of the with:                                              reactor head
Verify rod drop time of each rod, from the fully withdrawn position, is~ 2.7 seconds from the beginning of decay of stationary gripper coil voltage to dashpot entry, with: a. Tavg 550&deg;F; and b. All reactor coolant pumps operating.
: a. Tavg ~ 550&deg;F; and
BYRON -UNITS 1 & 2 3.1.4-4 COMPLETION TIME 6 hours FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Prior to criticality after each removal of the reactor head Amendment 202 Shutdown Bank Insertion Limits 3.1.5 3.1 REACTIVITY CONTROL SYSTEMS 3.1.5 Shutdown Bank Insertion Limits LCO 3.1. 5 Each shutdown bank shall be within the insertion limits specified in the COLR. ----------------------------NOTE----------------------------
: b. All reactor coolant pumps operating.
Not applicable to shutdown banks inserted while performing SR 3.1.4.2. APPLICABILITY:
BYRON - UNITS 1 &2                     3.1.4-4                         Amendment 202
MODES 1 and 2. ACTIONS CONDITION A. One shutdown bank inserted~
 
16 steps beyond the insertion limits specified in the COLR. BYRON -UNITS 1 & 2 A.l AND REQUIRED ACTION COMPLETION TIME Verify all control 1 hour banks are within the insertion limits specified in the COLR. A. 2 .1 Verify SOM is within 1 hour the limits specified in the COLR. A. 2. 2 Initiate borati on to 1 hour restore SOM to within limit. AND A.3 Restore the shutdown 24 hours bank to within the insertion limits specified in the COLR. (continued) 3.1.5-1 Amendment 202 Shutdown Bank Insertion Limits 3.1.5 ACTIONS (continued)
Shutdown Bank Insertion Limits 3.1.5 3.1 REACTIVITY CONTROL SYSTEMS 3.1.5 Shutdown Bank Insertion Limits LCO 3.1. 5       Each shutdown bank shall be within the insertion limits specified in the COLR.
CONDITION REQUIRED ACTION B. One or more shutdown B.1.1 Verify SOM is within banks not within the limits specified limits for reasons in the COLR. other than Condition A. OR B.1.2 Initiate boration to restore SOM to within limit. AND B.2 Restore shutdown bank(s) to within limits. C. Required Action and associated Completion C.l Be in MODE 3. Time not met. SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.1.5.1 Verify each shutdown bank is within the insertion limits specified in the COLR. BYRON -UNITS 1 & 2 3.1.5-2 COMPLETION TIME 1 hour 1 hour 2 hours 6 hours FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment 202 Control Bank Insertion Limits 3.1.6 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 Control Bank Insertion Limits LCD 3.1.6 Each control bank shall be within the insertion, sequence, and overlap limits specified in the COLR. ----------------------------NOTE----------------------------
                  ----------------------------NOTE----------------------------
Not applicable to control banks inserted while performing SR 3.1.4.2. APPLICABILITY:
Not applicable to shutdown banks inserted while performing SR 3.1.4.2.
MODE 1, MODE 2 with keff 1.0. ACTIONS CONDITION REQU I RED ACTION COMPLETI,ON TIME A. Control bank A, B or C A.l inserted~
APPLICABILITY:   MODES 1 and 2.
16 steps Verify all shutdown 1 hour banks are within the insertion limits beyond the insertion, sequence, or overlap limits specified in the COLR. BYRON -UNITS 1 & 2 specified in the COLR. AND A.2.1 Verify SOM is within 1 hour the limits specified in the COLR. A. 2. 2 Initiate borati on to 1 hour restore SOM to within limit. AND A.3 Restore the control 24 hours bank to within the insertion, sequence, and overlap limits specified in the COLR. (continued) 3.1.6-1 Amendment 202 ACTIONS (continued)
ACTIONS CONDITION                     REQUIRED ACTION          COMPLETION TIME A. One shutdown bank         A.l       Verify all control     1 hour inserted~ 16 steps                  banks are within the beyond the insertion                insertion limits limits specified in                  specified in the the COLR.                            COLR.
CONDITION B. Control bank insertion limits not met for reasons other than Condition A. C. Control bank sequence or overlap limits not met for reasons other than Condition A. D. Required Action and associated Completion Time not met. BYRON -UNITS 1 & 2 B.1.1 OR B.1.2 AND B.2 C.1.1 OR .C.1.2 AND C.2 D.l Control Bank Insertion Limits 3.1.6 REQUIRED ACTION COMPLETION TIME Verify SOM is within 1 hour the limits specified in the COLR. Initiate boration to 1 hour restore SOM to within limit. Restore control 2 hours bank(s) to within limits. Verify SOM is within 1 hour the limits specified in the COLR. Initiate boration to 1 hour restore SOM to within limit. Restore control bank 2 hours sequence and overlap to within limits. Be in MODE 2 with 6 hours keff < 1.0. 3.1.6-2 Amendment 202 Control Bank Insertion Limits 3.1.6 SURVEILLANCE REQUIREMENTS SR 3.1.6.1 SR 3.1.6.2 SR 3.1.6.3 SURVEILLANCE Verify estimated critical control bank position is within the limits specified in the COLR. Verify each control bank is within the insertion limits specified in the COLR. Verify each control bank not fully withdrawn from the core is within the sequence and overlap limits specified in the COLR. BYRON -UNITS 1 & 2 3.1.6-3 FREQUENCY Within 4 hours prior to criticality In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment 202 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Rod Position Indication Rod Position Indication 3.1. 7 LCD 3.1.7 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.
AND A. 2.1     Verify SOM is within   1 hour the limits specified in the COLR.
APPLICABILITY:
A. 2. 2   Initiate borati on to 1 hour restore SOM to within limit.
MODES 1 and 2. ACTIONS -------------------------------------NOTE-------------------------------------
AND A.3       Restore the shutdown   24 hours bank to within the insertion limits specified in the COLR.
(continued)
BYRON - UNITS 1 &2                    3.1.5-1                     Amendment   202
 
Shutdown Bank Insertion Limits 3.1.5 ACTIONS (continued)
CONDITION                   REQUIRED ACTION           COMPLETION TIME B. One or more shutdown       B.1.1   Verify SOM is within   1 hour banks not within                   the limits specified limits for reasons                 in the COLR.
other than Condition A.                 OR B.1.2   Initiate boration to   1 hour restore SOM to within limit.
AND B.2     Restore shutdown       2 hours bank(s) to within limits.
C. Required Action and     C.l     Be in MODE 3.           6 hours associated Completion Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                               FREQUENCY SR 3.1.5.1     Verify each shutdown bank is within the         In accordance insertion limits specified in the COLR.         with the Surveillance Frequency Control Program BYRON - UNITS 1 &2                   3.1.5-2                       Amendment 202
 
Control Bank Insertion Limits 3.1.6 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 Control Bank Insertion Limits LCD 3.1.6         Each control bank shall be within the insertion, sequence, and overlap limits specified in the COLR.
                  ----------------------------NOTE----------------------------
Not applicable to control banks inserted while performing SR 3.1.4.2.
APPLICABILITY:   MODE 1, MODE 2 with keff ~  1.0.
ACTIONS CONDITION                     REQU I RED ACTION         COMPLETI,ON TIME A. Control bank A, B or C A.l           Verify all shutdown     1 hour inserted~ 16 steps                  banks are within the beyond the insertion,               insertion limits sequence, or overlap               specified in the limits specified in                 COLR.
the COLR.
AND A.2.1     Verify SOM is within     1 hour the limits specified in the COLR.
A. 2. 2   Initiate borati on to   1 hour restore SOM to within limit.
AND A.3       Restore the control     24 hours bank to within the insertion, sequence, and overlap limits specified in the COLR.
(continued)
BYRON - UNITS 1 &2                    3.1.6-1                       Amendment 202
 
Control Bank Insertion Limits 3.1.6 ACTIONS (continued)
CONDITION               REQUIRED ACTION          COMPLETION TIME B. Control bank insertion B.1.1  Verify SOM is within    1 hour limits not met for             the limits specified reasons other than             in the COLR.
Condition A.
OR B.1.2   Initiate boration to     1 hour restore SOM to within limit.
AND B.2    Restore control         2 hours bank(s) to within limits.
C. Control bank sequence  C.1.1  Verify SOM is within     1 hour or overlap limits not          the limits specified met for reasons other          in the COLR.
than Condition A.
OR
                            .C.1.2    Initiate boration to   1 hour restore SOM to within limit.
AND C.2      Restore control bank   2 hours sequence and overlap to within limits.
D. Required Action and    D.l      Be in MODE 2 with       6 hours associated Completion          keff < 1.0.
Time not met.
BYRON - UNITS 1 &2                3.1.6-2                       Amendment   202
 
Control Bank Insertion Limits 3.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE                            FREQUENCY SR 3.1.6.1     Verify estimated critical control bank       Within 4 hours position is within the limits specified in   prior to the COLR.                                     criticality SR 3.1.6.2    Verify each control bank is within the       In accordance insertion limits specified in the COLR.       with the Surveillance Frequency Control Program SR 3.1.6.3    Verify each control bank not fully           In accordance withdrawn from the core is within the        with the sequence and overlap limits specified in     Surveillance the COLR.                                     Frequency Control Program BYRON - UNITS 1 &2                 3.1.6-3                     Amendment   202
 
Rod Position Indication 3.1. 7 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Rod Position Indication LCD 3.1.7         The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.
APPLICABILITY:   MODES 1 and 2.
ACTIONS
-------------------------------------NOTE-------------------------------------
Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.
Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.
CONDITION A. One DRPI per group inoperable in one or more groups. BYRON -UNITS 1 & 2 A.l OR A.2 REQUIRED ACTION Verify the position of the rods with inoperable DRPis. Verify the position of the rods with inoperable DRPis. 3.1.7-1 COMPLETION TIME Once per 8 hours 8 hours AND Once per 31 EFPD thereafter AND 8 hours after discovery of each unintended rod movement (continued)
CONDITION                   REQUIRED ACTION          COMPLETION TIME A. One DRPI per group         A.l     Verify the position     Once per 8 hours inoperable in one or              of the rods with more groups.                      inoperable DRPis.
Amendment 202 CONDITION A. (continued)
OR A.2    Verify the position     8 hours of the rods with inoperable DRPis.       AND Once per 31 EFPD thereafter AND 8 hours after discovery of each unintended rod movement (continued)
OR A.3 B. More than one DRPI per B.1 group inoperable in one or more groups. AND B.2 BYRON -UNITS 1 & 2 Rod Position Indication 3.1. 7 REQU I RED ACTION COMPLETION TIME 8 hours after each movement of rod with inoperable DRPI > 12 steps AND Prior to THERMAL POWER exceeding 50% RTP AND 8 hours after reaching RTP Reduce THERMAL POWER 8 Hours to 50% RTP. Place the control Immediately rods under manual control. Restore inoperable 24 hours DRPis to OPERABLE status such that a maximum of one DRPI per grou~ is inoperab e (continued) 3.1.7-2 Amendment 202 ACTIONS (continued)
BYRON - UNITS 1 &2                 3.1.7-1                   Amendment 202
CONDITION C. One or more DRPis inoperable in one or more groups and associated rod has been moved> 24 steps in one direction since the last determination of the rod's position.
D. One or more demand position indicators per bank inoperable in one or more banks. E. Required Action and associated Completion Time not met. BYRON -UNITS 1 & 2 C.l OR C.2 0.1.1 AND 0.1.2 OR 0.2 E. l Rod Position Indication 3.1. 7 REQUIRED ACTION COMPLETION TIME Initiate action to Inmediately verify the position of the rods with inoperable DRPis. Reduce THERMAL POWER 8 hours to s 50% RTP. Verify by Once per 8 hours administrative means all DRPis for the affected bank(s) are OPERABLE.
Verify the most Once per 8 hours withdrawn rod and the least withdrawn rod of the affected bank(s) are s 12 steps apart. Reduce THERMAL POWER 8 hours to s 50% RTP*. Be in MODE 3. 6 hours 3.1.7-3 Amendment 202 Rod Position Indication 3.1. 7 SURVEILLANCE REQUIREMENTS SR 3 .1. 7 .1 SURVEILLANCE
------------------NOTE---------------------
Not required to be met for DRPis associated with rods that do not meet LCD 3.1.4. Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel. BYRON -UNITS 1 & 2 3.1.7-4 FREQUENCY Prior to criticality after each removal of the reactor head Amendment 202 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 196 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-72, AMENDMENT NO. 196 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-77, AMENDMENT NO. 202 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-37, AND AMENDMENT NO. 202 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-66 EXELON GENERATION COMPANY, LLC


==1.0 INTRODUCTION==
Rod Position Indication 3.1. 7 CONDITION            REQU I RED ACTION        COMPLETION TIME A.  (continued)                                        8 hours after each movement of rod with inoperable DRPI
                                                        > 12 steps AND Prior to THERMAL POWER exceeding 50% RTP AND 8 hours after reaching RTP OR A.3  Reduce THERMAL POWER    8 Hours to ~ 50% RTP.
B. More than one DRPI per B.1  Place the control        Immediately group inoperable in        rods under manual one or more groups.        control.
AND B.2  Restore inoperable      24 hours DRPis to OPERABLE status such that a maximum of one DRPI per grou~ is inoperab e (continued)
BYRON - UNITS 1 &2            3.1.7-2                  Amendment 202


BRAIDWOOD STATION, UNITS 1 AND 2 BYRON STATION, UNIT NOS. 1 AND 2 DOCKET NOS. STN 50-456, STN 50-457, STN 50-454, AND STN 50-455 By letter dated June 30, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17187A191), as supplemented by letters dated October 25, 2017 (ADAMS Accession No. ML172989536) and May 29, 2018 (ADAMS Accession No. ML18149A637), Exelon Generation Company, LLC, (EGC, the licensee) submitted a license amendment request (LAR) to revise the technical specifications (TS) for Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2, to the U.S. Nuclear Regulatory Commission (NRC, the Commission).
Rod Position Indication 3.1. 7 ACTIONS (continued)
The supplements dated October 25, 2017 and May 29, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on August 29, 2017 (82 FR 41069). Specifically, the application requests changes consistent with NRC-approved Technical Specifications Task Force {TSTF) Change Traveler TSTF-547, Revision 1, "Clarification of Rod Position Requirements." By letter dated December 31, 2015 (ADAMS Accession No. ML15365A610), the TSTF submitted to the NRC Revision 1 to Change Traveler TSTF-547.
CONDITION                  REQUIRED ACTION          COMPLETION TIME C. One or more DRPis      C.l      Initiate action to     Inmediately inoperable in one or            verify the position more groups and                 of the rods with associated rod has              inoperable DRPis.
Change Traveler TSTF-547 proposes changes to Volumes 1 and 2 of NUREG-1431, Revision 4, "Standard Technical Specifications:
been moved> 24 steps in one direction since OR the last determination of the rod's position. C.2      Reduce THERMAL POWER    8 hours to s 50% RTP.
Westinghouse Plants," dated April 2012 (ADAMS Accession Nos. ML12100A222 and ML12100A228, respectively).
D. One or more demand      0.1.1     Verify by               Once per 8 hours position indicators              administrative means per bank inoperable              all DRPis for the in one or more banks.           affected bank(s) are OPERABLE.
The proposed changes would revise the TS to provide time to repair rod movement failures that do not affect Enclosure 5  rod operability, correct conflicts between the TS, and increase consistency between the subject TS and improve the format and presentation.
AND 0.1.2    Verify the most        Once per 8 hours withdrawn rod and the least withdrawn rod of the affected bank(s) are s 12 steps apart.
1.1 Description of Rod Cluster Control Assemblies The rod cluster control assemblies (RCCA), or rods, are moved by their control rod drive mechanisms (CRDM). Each CRDM moves its RCCA one step (approximately 5/8 inch) at a time, but at varying rates (steps per minute) depending on the signal output from the rod control system. The RCCAs are divided among control banks and shutdown banks. Each bank may be further subdivided into two groups to provide for precise reactivity control. A group consists of two or more RCCAs that step simultaneously.
OR 0.2      Reduce THERMAL POWER    8 hours to s 50% RTP*.
If a bank of RCCAs consists of two groups, the groups are moved in a staggered fashion, but always within one step of each other. All units have four control banks and five shutdown banks. The shutdown banks are maintained either in the fully inserted or fully withdrawn position.
E. Required Action and   E. l      Be in MODE 3.           6 hours associated Completion Time not met.
The control banks are moved in an overlap pattern using the following withdrawal sequence:
BYRON - UNITS 1 &2                3.1.7-3                  Amendment 202
when control bank A reaches a predetermined height in the core, control bank B begins to move out with control bank A. Control bank A stops at the position of maximum withdrawal, and control bank B continues to move out. When control bank B reaches a predetermined height, control bank C begins to move out with control bank B. This sequence continues until control banks A, B, and C are at the fully withdrawn position, and control bank D is approximately halfway withdrawn.
The insertion sequence is the opposite of the withdrawal sequence.
The control rods are arranged in a radially symmetric pattern, so that control bank motion does not introduce radial asymmetries in the core power distributions.
The control banks are used for precise reactivity control of the reactor. The positions of the control banks are normally automatically controlled by the rod control system, but they can also be manually controlled.
They are capable of adding negative reactivity very quickly (compared to adding soluble boron). The control banks must be maintained above designed insertion limits and three of the four are typically near the fully withdrawn position during normal full power operations.
The axial position of shutdown rods and control rods is indicated by two separate and independent systems, which are the demand position indication system (commonly called group step counters) and the digital rod position indication (DRPI) system. The demand position indication system counts the pulses from the rod control system that moves the rods. There is one step counter for each group of rods. Individual rods in a group all receive the same signal to move and should, therefore, all be at the same position indicated by the group step counter for that group. The demand position indication system is considered highly precise (+/-1 step or +/-5/8 inch); however, it is not a reliable indicator of rod position because it is a demanded position indication, not an actual position indication.
If a rod does not move one step for each demand pulse, the step counter will still count the pulse but incorrectly reflect the position of the rod. The DRPI system provides a more reliable indication of actual rod position, but at a lower precision than the step counters.
This system is based on inductive analog signals from a series of coils spaced along a hollow tube with a center to center distance of 3. 75 inches or 6 steps. To increase the reliability of the system, the inductive coils are connected alternately to data channel A or B. Thus, if one data system fails, the DRPI will indicate rod position with an effective coil spacing of 7.5 inches or 12 steps. The DRPI system is capable of monitoring rod position within at least +/-12 steps. 


==2.0 REGULATORY EVALUATION==
Rod Position Indication 3.1. 7 SURVEILLANCE REQUIREMENTS SURVEILLANCE                            FREQUENCY SR 3.1. 7.1    ------------------NOTE---------------------  Prior to Not required to be met for DRPis associated  criticality with rods that do not meet LCD 3.1.4.        after each removal of the reactor head Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel.
BYRON - UNITS 1 &2                 3.1.7-4                Amendment 202


The categories of items required to be in the TSs are provided in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c).
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 196 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-72, AMENDMENT NO. 196 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-77, AMENDMENT NO. 202 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-37, AND AMENDMENT NO. 202 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-66 EXELON GENERATION COMPANY, LLC BRAIDWOOD STATION, UNITS 1 AND 2 BYRON STATION, UNIT NOS. 1 AND 2 DOCKET NOS. STN 50-456, STN 50-457, STN 50-454, AND STN 50-455
As required by 10 CFR 50.36(c)(2)(i), the TSs will include limiting conditions for operations (LCOs), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility.
 
Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met. The regulation at 10 CFR 50.36(c)(3) requires TSs to include items in the category of surveillance requirements (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 LCOs will be met. Also, 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TSs. The NRC staff's guidance for the review of TSs is in Chapter 16, "Technical Specifications," of NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition" (March 2010) (ADAMS Accession No. ML100351425).
==1.0    INTRODUCTION==
As described therein, as part of the regulatory standardization effort, the NRC staff has prepared Standard Technical Specifications (STSs) for each of the LWR nuclear designs. NUREG-1431, Revision 4, contains the STSs for Westinghouse-designed plants. 3.0 3.1 TECHNICAL EVALUATION Description of Proposed Changes This safety evaluation (SE) addresses proposed changes to TS 3.1.4, "Rod Group Alignment Limits," TS 3.1.5, "Shutdown Bank Insertion Limits," TS 3.1.6, "Control Bank Insertion Limits," and TS 3.1.7, "Rod Position Indication." The specific proposed changes are described in the following subsections.
 
The discussion is applicable to both Braidwood and Byron Stations.
By letter dated June 30, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17187A191), as supplemented by letters dated October 25, 2017 (ADAMS Accession No. ML172989536) and May 29, 2018 (ADAMS Accession No.
3.1.1 Provide Time to Correct Rod Movement Failures that Do Not Affect Operability The current TS 3.1.5 states in part: LCO 3.1.5 Each shutdown bank shall be within the insertion limits specified in the COLR. -------------------------
ML18149A637), Exelon Generation Company, LLC, (EGC, the licensee) submitted a license amendment request (LAR) to revise the technical specifications (TS) for Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2, to the U.S. Nuclear Regulatory Commission (NRC, the Commission). The supplements dated October 25, 2017 and May 29, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on August 29, 2017 (82 FR 41069).
NOTE --------------------------
Specifically, the application requests changes consistent with NRC-approved Technical Specifications Task Force {TSTF) Change Traveler TSTF-547, Revision 1, "Clarification of Rod Position Requirements." By letter dated December 31, 2015 (ADAMS Accession No.
This LCO is not applicable while performing SR 3.1.4.2. APPLICABILITY:
ML15365A610), the TSTF submitted to the NRC Revision 1 to Change Traveler TSTF-547.
MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1.1 Verify SOM is 1 hour shutdown banks not within the limits within limits. specified in the COLR. OR  A.1.2 Initiate boration to 1 hour restore SDM to within limit. AND A.2 Restore shutdown 2 hours bank(s) to within limits. 8. Required Action and 8.1 Be in MODE 3. 6 hours associated Completion Time not met The proposed change would change the note to specifically refer to shutdown banks. The proposed change would add a new Condition A to TS 3.1.5 that would require actions with one shutdown bank inserted s 16 steps beyond the insertion limits specified in the core operating limit report (COLR). The existing Condition A would be renumbered as Condition 8 and would be modified to apply for one or more shutdown banks not within limits for reasons other than Condition A. The existing Required Actions (RAs) A.1.1, A.1.2, and A.2, would be renumbered as 8.1.1, 8.1.2, and 8.2. The existing Condition 8 and RA 8.1 would be renumbered as Condition C and RAC.1. The shutdown banks must be within their insertion limits any time the reactor is critical or approaching criticality.
Change Traveler TSTF-547 proposes changes to Volumes 1 and 2 of NUREG-1431, Revision 4, "Standard Technical Specifications: Westinghouse Plants," dated April 2012 (ADAMS Accession Nos. ML12100A222 and ML12100A228, respectively). The proposed changes would revise the TS to provide time to repair rod movement failures that do not affect Enclosure 5
This ensures that a sufficient amount of negative reactivity is available to shut down the reactor and maintain the required shutdown margin (SDM) following a reactor trip. Therefore proposed TS 3.1.5 would state: LCO 3.1.5 Each shutdown bank shall be within the insertion limits specified in the COLR. -------------------------
 
NOTE --------------------------
rod operability, correct conflicts between the TS, and increase consistency between the subject TS and improve the format and presentation.
Not applicable to shutdown banks inserted while performing SR 3.1.4.2. APPLICABILITY:
1.1     Description of Rod Cluster Control Assemblies The rod cluster control assemblies (RCCA), or rods, are moved by their control rod drive mechanisms (CRDM). Each CRDM moves its RCCA one step (approximately 5/8 inch) at a time, but at varying rates (steps per minute) depending on the signal output from the rod control system. The RCCAs are divided among control banks and shutdown banks. Each bank may be further subdivided into two groups to provide for precise reactivity control. A group consists of two or more RCCAs that step simultaneously. If a bank of RCCAs consists of two groups, the groups are moved in a staggered fashion, but always within one step of each other. All units have four control banks and five shutdown banks.
MODES 1 and 2. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One shutdown bank A.1 Verify all control 1 hour inserted s 16 steps banks are within the beyond the insertion insertion limits limits specified in the specified in the COLR. COLR. AND  A.2.1 Verify SDM is within 1 hour the limits specified in the COLR. OR A.2.2 Initiate boration to 1 hour restore SDM to within limit. AND A.3 Restore the 24 hours shutdown bank to within the insertion limits specified in the COLR. B. One or more B.1.1 Verify SDM is 1 hour shutdown banks not within the limits within limits for specified in the reasons other than COLR. Condition A. OR B.1.2 Initiate boration to 1 hour restore SDM to within limit. AND B.2 Restore shutdown 2 hours bank( s) to within limits. C. Required Action and C. 1 Be in MODE 3. 6 hours associated Completion Time not met. The current TS 3.1.6 states, in part: LCO 3.1.6 Each control bank shall be within the insertion, sequence, and overlap limits specified in the COLR. -------------------------
The shutdown banks are maintained either in the fully inserted or fully withdrawn position. The control banks are moved in an overlap pattern using the following withdrawal sequence: when control bank A reaches a predetermined height in the core, control bank B begins to move out with control bank A. Control bank A stops at the position of maximum withdrawal, and control bank B continues to move out. When control bank B reaches a predetermined height, control bank C begins to move out with control bank B. This sequence continues until control banks A, B, and C are at the fully withdrawn position, and control bank D is approximately halfway withdrawn. The insertion sequence is the opposite of the withdrawal sequence. The control rods are arranged in a radially symmetric pattern, so that control bank motion does not introduce radial asymmetries in the core power distributions.
NOTE --------------------------
The control banks are used for precise reactivity control of the reactor. The positions of the control banks are normally automatically controlled by the rod control system, but they can also be manually controlled. They are capable of adding negative reactivity very quickly (compared to adding soluble boron). The control banks must be maintained above designed insertion limits and three of the four are typically near the fully withdrawn position during normal full power operations.
This LCO is not applicable while performing SR 3.1.4.2. APPLICABILITY:
The axial position of shutdown rods and control rods is indicated by two separate and independent systems, which are the demand position indication system (commonly called group step counters) and the digital rod position indication (DRPI) system. The demand position indication system counts the pulses from the rod control system that moves the rods. There is one step counter for each group of rods. Individual rods in a group all receive the same signal to move and should, therefore, all be at the same position indicated by the group step counter for that group. The demand position indication system is considered highly precise (+/-1 step or
MODE 1, MODE 2 with l<eff 2::: 1.0. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Control bank insertion A.1.1 Verify SOM is within 1 hour limits not met. the limits specified in the COLR. OR A.1.2 Initiate boration to 1 hour restore SOM to within limit. AND A.2 Restore control 2 hours bank(s) to within limits. B. Control bank B.1.1 Verify SOM is within 1 hour sequence or overlap the limits specified limits not met. in the COLR. OR B.1.2 Initiate boration to restore SOM to 1 hour within limit. AND B.2 Restore control bank sequence and 2 hours overlap to within limits. C. Required Action and C.1 Be in MODE 2 with 6 hours associated l<eff < 1.0. Completion Time not met. The proposed change would change the note to specifically refer to control banks. The proposed change would add a new Condition A to TS 3.1.6 that would require actions, if control bank A, B, or C is inserted s 16 steps beyond the insertion, sequence, and overlap limits specified in the COLR. The existing Condition A would be renumbered as Condition B and would be modified to apply for control bank insertion limits that are not met for reasons other than Condition A. The existing RAs A.1.1, A.1.2, and A.2, would be renumbered as 8.1.1, B.1.2, and B.2. The existing Condition B would be renumbered as Condition C and would be modified to apply when control bank sequence or overlap limits are not met for reasons other than Condition A. The existing RAs B.1.1, B.1.2, and 8.2 would be renumbered as C.1.1, C.1.2, and C.2. Existing Condition C and RA C.1 would be renumbered as Condition D and RA D.1. The limits on control banks sequence, overlap, and physical insertion, as defined in the COLR, must be maintained because they serve the function of preserving power distribution, ensuring that the SDM is maintained, ensuring that ejected rod worth is maintained, and ensuring adequate negative reactivity insertion is available on trip. Therefore, proposed TS 3.1.6 would state: LCO 3.1.6 Each control bank shall be within the insertion, sequence, and overlap limits specified in the COLR. -------------------------
+/-5/8 inch); however, it is not a reliable indicator of rod position because it is a demanded position indication, not an actual position indication. If a rod does not move one step for each demand pulse, the step counter will still count the pulse but incorrectly reflect the position of the rod.
NOTE --------------------------
The DRPI system provides a more reliable indication of actual rod position, but at a lower precision than the step counters. This system is based on inductive analog signals from a series of coils spaced along a hollow tube with a center to center distance of 3. 75 inches or 6 steps. To increase the reliability of the system, the inductive coils are connected alternately to data channel A or B. Thus, if one data system fails, the DRPI will indicate rod position with an effective coil spacing of 7.5 inches or 12 steps. The DRPI system is capable of monitoring rod position within at least +/-12 steps.
Not applicable to control banks inserted while performing SR 3.1.4.2. APPLICABILITY:
 
MODE 1, MODE 2 with Keff:::::
==2.0      REGULATORY EVALUATION==
1.0. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Control bank A, B or A.1 Verify all shutdown 1 hour C inserted s 16 steps banks are within the beyond the insertion, insertion limits sequence,oroverlap specified in the limits specified in the COLR. COLR. AND A.2.1 Verify SDM is within 1 hour the limits specified in the COLR. OR A.2.2 Initiate boration to 1 hour restore SDM to within limit. AND A.3 Restore the control 24 hours bank to within the insertion, sequence, and overlap limits specified in the COLR. B. Control bank insertion B.1.1 Verify SDM is within 1 hour limits not met for the limits specified reasons other than in the COLR. Condition A. OR  B.1.2 Initiate boration to 1 hour restore SOM to within limit. AND 8.2 Restore control 2 hours bank( s) to within limits. C. Control bank C.1.1 Verify SOM is within 1 hour sequence or overlap the limits specified limits not met for in the COLR. reasons other than Condition A. OR C.1.2 Initiate boration to 1 hour restore SOM to within limit. AND C.2 Restore control 2 hours bank sequence and overlap to within limits. D. Required Action and D.1 Be in MODE 2 with 6 hours associated keff < 1.0. Completion Time not met. 3.1.2 Provide an Alternative to Frequent Verification of Rod Position The current TS 3.1. 7 states, in part: LCO 3.1.7 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.
 
APPLICABILITY:
The categories of items required to be in the TSs are provided in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c). As required by 10 CFR 50.36(c)(2)(i), the TSs will include limiting conditions for operations (LCOs), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met. The regulation at 10 CFR 50.36(c)(3) requires TSs to include items in the category of surveillance requirements (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 LCOs will be met. Also, 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TSs.
MODES 1 and 2. ACTIONS -------------------------
The NRC staff's guidance for the review of TSs is in Chapter 16, "Technical Specifications," of NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition" (March 2010) (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared Standard Technical Specifications (STSs) for each of the LWR nuclear designs. NUREG-1431, Revision 4, contains the STSs for Westinghouse-designed plants.
NOTE --------------------------
 
==3.0      TECHNICAL EVALUATION==
 
3.1     Description of Proposed Changes This safety evaluation (SE) addresses proposed changes to TS 3.1.4, "Rod Group Alignment Limits," TS 3.1.5, "Shutdown Bank Insertion Limits," TS 3.1.6, "Control Bank Insertion Limits,"
and TS 3.1.7, "Rod Position Indication." The specific proposed changes are described in the following subsections. The discussion is applicable to both Braidwood and Byron Stations.
3.1.1    Provide Time to Correct Rod Movement Failures that Do Not Affect Operability The current TS 3.1.5 states in part:
LCO     3.1.5    Each shutdown bank shall be within the insertion limits specified in the COLR.
                  - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - -
This LCO is not applicable while performing SR 3.1.4.2.
APPLICABILITY:              MODES 1 and 2.
ACTIONS CONDITION                              REQUIRED ACTION                          COMPLETION TIME A. One or more                            A.1.1 Verify SOM is                  1 hour shutdown banks not                                within the limits within limits.                                    specified in the COLR.
OR
 
A.1.2      Initiate boration to     1 hour restore SDM to within limit.
AND A.2       Restore shutdown          2 hours bank(s) to within limits.
: 8. Required Action and                    8.1       Be in MODE 3.             6 hours associated Completion Time not met The proposed change would change the note to specifically refer to shutdown banks.
The proposed change would add a new Condition A to TS 3.1.5 that would require actions with one shutdown bank inserted s 16 steps beyond the insertion limits specified in the core operating limit report (COLR).
The existing Condition A would be renumbered as Condition 8 and would be modified to apply for one or more shutdown banks not within limits for reasons other than Condition A. The existing Required Actions (RAs) A.1.1, A.1.2, and A.2, would be renumbered as 8.1.1, 8.1.2, and 8.2. The existing Condition 8 and RA 8.1 would be renumbered as Condition C and RAC.1.
The shutdown banks must be within their insertion limits any time the reactor is critical or approaching criticality. This ensures that a sufficient amount of negative reactivity is available to shut down the reactor and maintain the required shutdown margin (SDM) following a reactor trip.
Therefore proposed TS 3.1.5 would state:
LCO    3.1.5  Each shutdown bank shall be within the insertion limits specified in the COLR.
                - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - -
Not applicable to shutdown banks inserted while performing SR 3.1.4.2.
APPLICABILITY:            MODES 1 and 2.
ACTIONS CONDITION                              REQUIRED ACTION                          COMPLETION TIME A. One shutdown bank                      A.1       Verify all control        1 hour inserted s 16 steps                              banks are within the beyond the insertion                              insertion limits limits specified in the                          specified in the COLR.                                            COLR.
AND
 
A.2.1    Verify SDM is within        1 hour the limits specified in the COLR.
OR A.2.2      Initiate boration to      1 hour restore SDM to within limit.
AND A.3       Restore the                24 hours shutdown bank to within the insertion limits specified in the COLR.
B. One or more                            B.1.1      Verify SDM is            1 hour shutdown banks not                              within the limits within limits for                                specified in the reasons other than                                COLR.
Condition A.
OR B.1.2      Initiate boration to     1 hour restore SDM to within limit.
AND B.2       Restore shutdown          2 hours bank( s) to within limits.
C. Required Action and                    C. 1       Be in MODE 3.              6 hours associated Completion Time not met.
The current TS 3.1.6 states, in part:
LCO    3.1.6  Each control bank shall be within the insertion, sequence, and overlap limits specified in the COLR.
              - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - -
This LCO is not applicable while performing SR 3.1.4.2.
APPLICABILITY:            MODE 1, MODE 2 with l<eff 2::: 1.0.
 
ACTIONS CONDITION                      REQUIRED ACTION                COMPLETION TIME A. Control bank insertion          A.1.1 Verify SOM is within    1 hour limits not met.                      the limits specified in the COLR.
OR A.1.2    Initiate boration to  1 hour restore SOM to within limit.
AND A.2   Restore control         2 hours bank(s) to within limits.
B. Control bank                   B.1.1 Verify SOM is within   1 hour sequence or overlap                   the limits specified limits not met.                        in the COLR.
OR B.1.2 Initiate boration to restore SOM to         1 hour within limit.
AND B.2     Restore control bank sequence and     2 hours overlap to within limits.
C. Required Action and             C.1     Be in MODE 2 with     6 hours associated                             l<eff < 1.0.
Completion Time not met.
The proposed change would change the note to specifically refer to control banks.
The proposed change would add a new Condition A to TS 3.1.6 that would require actions, if control bank A, B, or C is inserted s 16 steps beyond the insertion, sequence, and overlap limits specified in the COLR.
The existing Condition A would be renumbered as Condition B and would be modified to apply for control bank insertion limits that are not met for reasons other than Condition A. The existing RAs A.1.1, A.1.2, and A.2, would be renumbered as 8.1.1, B.1.2, and B.2.
The existing Condition B would be renumbered as Condition C and would be modified to apply when control bank sequence or overlap limits are not met for reasons other than Condition A.
The existing RAs B.1.1, B.1.2, and 8.2 would be renumbered as C.1.1, C.1.2, and C.2. Existing Condition C and RA C.1 would be renumbered as Condition D and RA D.1.
 
The limits on control banks sequence, overlap, and physical insertion, as defined in the COLR, must be maintained because they serve the function of preserving power distribution, ensuring that the SDM is maintained, ensuring that ejected rod worth is maintained, and ensuring adequate negative reactivity insertion is available on trip.
Therefore, proposed TS 3.1.6 would state:
LCO     3.1.6  Each control bank shall be within the insertion, sequence, and overlap limits specified in the COLR.
                - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - -
Not applicable to control banks inserted while performing SR 3.1.4.2.
APPLICABILITY:            MODE 1, MODE 2 with Keff::::: 1.0.
ACTIONS CONDITION                              REQUIRED ACTION                          COMPLETION TIME A. Control bank A, B or                  A.1        Verify all shutdown        1 hour C inserted s 16 steps                            banks are within the beyond the insertion,                            insertion limits sequence,oroverlap                                specified in the limits specified in the                          COLR.
COLR.
AND A.2.1      Verify SDM is within      1 hour the limits specified in the COLR.
OR A.2.2      Initiate boration to        1 hour restore SDM to within limit.
AND A.3        Restore the control        24 hours bank to within the insertion, sequence, and overlap limits specified in the COLR.
B. Control bank insertion                B.1.1      Verify SDM is within        1 hour limits not met for                                the limits specified reasons other than                                in the COLR.
Condition A.
OR
 
B.1.2 Initiate boration to              1 hour restore SOM to within limit.
AND 8.2    Restore control                2 hours bank( s) to within limits.
C. Control bank                            C.1.1  Verify SOM is within            1 hour sequence or overlap                            the limits specified limits not met for                            in the COLR.
reasons other than Condition A.                              OR C.1.2 Initiate boration to              1 hour restore SOM to within limit.
AND C.2    Restore control                2 hours bank sequence and overlap to within limits.
D. Required Action and                      D.1    Be in MODE 2 with              6 hours associated                                    keff < 1.0.
Completion Time not met.
3.1.2      Provide an Alternative to Frequent Verification of Rod Position The current TS 3.1. 7 states, in part:
LCO        3.1.7    The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.
APPLICABILITY:                  MODES 1 and 2.
ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - -
Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.
Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.
CONDITION REQUIRED ACTION COMPLETION TIME A. One DRPI per group A.1 Verify the position Once per 8 hours inoperable for one or of the rods with more groups. inoperable DRPls. OR A.2 Reduce THERMAL 8 hours POWER to s 50% RTP. B. One or more rods with B.1 Initiate action to Immediately inoperable DRPls verify the position of have been moved in the rods with excess of 24 steps in inoperable DRPls. one direction since the last determination OR of the rod's position.
CONDITION                             REQUIRED ACTION                             COMPLETION TIME A. One DRPI per group                       A.1     Verify the position             Once per 8 hours inoperable for one or                         of the rods with more groups.                                   inoperable DRPls.
8.2 Reduce THERMAL 8 hours POWER to s 50% RTP. C. One demand position C.1.1 Verify by Once per 8 hours indicator per bank administrative inoperable for one or means all DRPls for more banks the affected bank(s) are OPERABLE.
 
AND C.1.2 Verify the most Once per 8 hours withdrawn rod and the least withdrawn rod of the affected bank(s) ares 12 steps apart. OR C.2 Reduce THERMAL 8 hours POWER to s 50% RTP. D. Required Action and D.1 Be in MODE 3. 6 hours associated Completion Time not met. The TS 3.1.7, "Rod Position Indication," requires that the DRPI system and the demand positon indication system be operable during Startup and Power Operation.
OR A.2   Reduce THERMAL         8 hours POWER to s 50%
Condition A applies for one DRPI per group of rods inoperable for one or more groups of rods. As noted in the TS Bases 3.1. 7, verification of rod position can be determined by use of either the moveable incore detectors or the Power Distribution Monitoring system (PDMS). The proposed change would add a new RA to Condition A as an alternative to the once per 8-hour verification of rod position.
RTP.
Also, an editorial change would be made to Condition A and Condition C to change "for'' to "in." This would not change the technical meaning of the Conditions. A new Condition B would be added. As noted above, the Braidwood and Byron TS were based on NUREG-1431, Revision 1, which did not have a condition for more than one DRPI per group inoperable.
B. One or more rods with         B.1   Initiate action to     Immediately inoperable DRPls                     verify the position of have been moved in                   the rods with excess of 24 steps in               inoperable DRPls.
The new Condition B and RAs would be incorporated into the Braidwood and Byron TS. As a result of this addition, the existing Condition B would be renumbered as Condition C, the existing Condition C would be renumbered as Condition D, and the existing Condition D would be renumbered as Condition E. The existing Condition B (renumbered as Condition C) would be revised to contain similar terminology to Condition A and the new Condition B for consistency.
one direction since the last determination       OR of the rod's position.
The existing Condition C (renumbered as Condition D), would be revised from "One demand position indicator per bank inoperable for one or more banks" to "One or more demand position indicators per bank inoperable in one or more banks." The proposed change would make the terminology consistent with the Note that states, "Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator." The 12-step agreement limit between the bank demand position indication system and the DRPI system indicates that the demand position indication system is adequately calibrated, and can be used for indication of the measurement of control rod bank position.
8.2   Reduce THERMAL         8 hours POWER to s 50%
When one DRPI per group fails, the position of the rod may still be determined indirectly by use of either the movable incore detectors or PDMS. Therefore, proposed TS 3.1. 7 would state: LCO 3.1. 7 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.
RTP.
APPLICABILITY:
C. One demand position           C.1.1 Verify by             Once per 8 hours indicator per bank                   administrative inoperable for one or               means all DRPls for more banks                           the affected bank(s) are OPERABLE.
MODES 1 and 2. ACTIONS -------------------------
AND C.1.2 Verify the most         Once per 8 hours withdrawn rod and the least withdrawn rod of the affected bank(s) ares 12 steps apart.
NOTE --------------------------
OR C.2     Reduce THERMAL       8 hours POWER to s 50%
RTP.
D. Required Action and           D.1     Be in MODE 3.         6 hours associated Completion Time not met.
The TS 3.1.7, "Rod Position Indication," requires that the DRPI system and the demand positon indication system be operable during Startup and Power Operation. Condition A applies for one DRPI per group of rods inoperable for one or more groups of rods.
As noted in the TS Bases 3.1. 7, verification of rod position can be determined by use of either the moveable incore detectors or the Power Distribution Monitoring system (PDMS).
The proposed change would add a new RA to Condition A as an alternative to the once per 8-hour verification of rod position. Also, an editorial change would be made to Condition A and Condition C to change "for'' to "in." This would not change the technical meaning of the Conditions.
 
A new Condition B would be added. As noted above, the Braidwood and Byron TS were based on NUREG-1431, Revision 1, which did not have a condition for more than one DRPI per group inoperable. The new Condition B and RAs would be incorporated into the Braidwood and Byron TS. As a result of this addition, the existing Condition B would be renumbered as Condition C, the existing Condition C would be renumbered as Condition D, and the existing Condition D would be renumbered as Condition E.
The existing Condition B (renumbered as Condition C) would be revised to contain similar terminology to Condition A and the new Condition B for consistency.
The existing Condition C (renumbered as Condition D), would be revised from "One demand position indicator per bank inoperable for one or more banks" to "One or more demand position indicators per bank inoperable in one or more banks." The proposed change would make the terminology consistent with the Note that states, "Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator."
The 12-step agreement limit between the bank demand position indication system and the DRPI system indicates that the demand position indication system is adequately calibrated, and can be used for indication of the measurement of control rod bank position. When one DRPI per group fails, the position of the rod may still be determined indirectly by use of either the movable incore detectors or PDMS.
Therefore, proposed TS 3.1. 7 would state:
LCO       3.1. 7   The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.
APPLICABILITY:                 MODES 1 and 2.
ACTIONS
- - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - -
Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.
Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.
CONDITION REQUIRED ACTION COMPLETION TIME A. One DRPI per group A.1 Verify the position Once per 8 hours inoperable in one or of the rods with more groups. inoperable DRPls. OR A.2 Verify the position 8 hours of the rods with inoperable DRPls AND Once per 31 EFPD thereafter AND   8 hours after discovery of each unintended rod movement AND 8 hours after each movement of rod with inoperable DRPI > 12 steps AND Prior to THERMAL POWER exceeding 50% RTP AND 8 hours after reaching RTP OR A.3 Reduce THERMAL 8 hours POWER to !:> 50% RTP. B. More than one DRPI B.1 Place the control Immediately per group inoperable rods under manual in one or more groups control. AND B.2 Restore inoperable 24 hours DRPls to OPERABLE status such that a maximum of one DRPI per group is inoperable.
CONDITION                             REQUIRED ACTION                             COMPLETION TIME A. One DRPI per group                       A.1     Verify the position             Once per 8 hours inoperable in one or                           of the rods with more groups.                                   inoperable DRPls.
C. One or more DRPls C. 1 Initiate action to Immediately inoperable in one or verify the position of more groups and the rods with associated rod has inoperable DRPls. been moved> 24 steps in one direction OR since the last C.2 Reduce THERMAL 8 hours   determination of the POWER to s 50% rod's position.
OR A.2     Verify the position             8 hours of the rods with inoperable DRPls                 AND Once per 31 EFPD thereafter AND
RTP. D. One or more demand D.1.1 Verify by position indicators per administrative bank inoperable in means all DRPls for one or more banks. the affected bank( s) are OPERABLE.
 
AND D.1.2 Verify the most withdrawn rod and the least withdrawn rod of the affected bank(s) ares 12 steps apart. OR D.2 Reduce THERMAL POWER to s 50% RTP. E. Required Action and E.1 Be in MODE 3. associated Completion Time not met. 3.1.3 Correct Conflicts Between TS 3.1.4 and TS 3.1. 7 The current SR 3.1.4.1 states: SURVEILLANCE Once per 8 hours Once per 8 hours 8 hours 6 hours FREQUENCY SR 3.1.4.1 Verify individual rod positions within alignment limit. In accordance with the Surveillance Frequency Control Program The SR 3.1.4.1 requires verification that individual rod positions are within the alignment limits in accordance with the surveillance frequency control program (SFCP). The proposed change is the addition of a Note to SR 3.1.4.1 stating that the SR is not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.
8 hours after discovery of each unintended rod movement AND 8 hours after each movement of rod with inoperable DRPI
This Note is proposed to be added because SR 3. 1.4. 1 cannot be performed for rods with an inoperable demand position indicator.
                                                      > 12 steps AND Prior to THERMAL POWER exceeding 50% RTP AND 8 hours after reaching RTP OR A.3 Reduce THERMAL         8 hours POWER to !:> 50%
An editorial wording change is also proposed for SR 3.1.4.1 to make it consistent with the wording of TS 3.1. 7 RA A.1. Therefore, proposed SR 3.1.4.1 would state:   SURVEILLANCE FREQUENCY SR 3.1.4.1 ------------------
RTP.
NOTE ---------------
B. More than one DRPI     B.1 Place the control     Immediately per group inoperable       rods under manual in one or more groups       control.
In accordance Not required to be performed for rods associated with the with inoperable rod position indicator or demand Surveillance position indicator.
AND B.2 Restore inoperable     24 hours DRPls to OPERABLE status such that a maximum of one DRPI per group is inoperable.
Frequency  
C. One or more DRPls     C. 1 Initiate action to     Immediately inoperable in one or       verify the position of more groups and             the rods with associated rod has         inoperable DRPls.
------------------------------------------
been moved> 24 steps in one direction OR since the last C.2 Reduce THERMAL         8 hours
Control Program Verify position of individual rods within alignment limit. The current SR 3.1. 7.1, states: SURVEILLANCE FREQUENCY SR 3.1.7.1 Verify each DRPI agrees within 12 steps of the group Prior to criticality after demand position for the full indicated range of rod each removal of the travel. reactor head The LCO 3.1.4 specifies that all shutdown and control rods shall be operable and individual indicated rod positions shall be within 12 steps of their group step counter demand position.
 
SR 3.1. 7.1 requires verification that each DRPI agrees within the required steps of the group demand position for the full indicated range of rod travel. The proposed change is the addition of a Note to SR 3.1. 7 .1 stating that the SR would not be required to be met for rods that do not meet LCO 3.1.4. Therefore, proposed SR 3.1.7.1 would state: SURVEILLANCE FREQUENCY SR 3.1.7.1 ------------------
determination of the                 POWER to s 50%
NOTE ---------------
rod's position.                       RTP.
Prior to criticality after Not required to be met for DRPls associated with each removal of the rods that do not meet LCO 3.1.4. reactor head ------------------------------------------
D. One or more demand             D.1.1   Verify by               Once per 8 hours position indicators per               administrative bank inoperable in                   means all DRPls for one or more banks.                   the affected bank( s) are OPERABLE.
Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel. 3.1.4 Other Proposed Changes The proposed changes described in this section are editorial and do not change the technical content. 1. TSTF-547 proposes to eliminate TS 3.1.4, Condition 8, RA 8.1, and to combine RAs 8.2.4 and 8.2.5. RA 8.1 was previously eliminated during the Braidwood and Byron Station TS transition from current technical specifications
AND D.1.2 Verify the most           Once per 8 hours withdrawn rod and the least withdrawn rod of the affected bank(s) ares 12 steps apart.
{CTS} to NUREG-1431, Revision 1. RAs 8.2.4 and 8.2.5 were previously combined in Amendment 110 (Braidwood Station) and Amendment 116 (Byron Station) (ADAMS Accession No. ML010510325).
OR D.2     Reduce THERMAL         8 hours POWER to s 50%
No additional changes are necessary.
RTP.
: 2. LCO 3.1.5 and LCO 3.1.6 contain a Note modifying their Applicability that states "This LCO is not applicable while performing SR 3.1.4.2." The proposed change would revise the Notes to state: "Not applicable to shutdown banks inserted while performing SR 3.1.4.2," for LCO 3.1.5; and "Not applicable to control banks inserted while   performing SR 3.1.4.2," for LCO 3.1.6. This change clarifies the Note and does not alter its meaning. 3. In TSTF-547, TS 3.1.7 is revised to consistently use the defined abbreviation "DRPI." This affects the Actions Note, RA A.1, RA B.2, and RA C.1. Consistent use of the defined abbreviation "DRPI" was previously adopted during the Braidwood and Byron Station TS transition from CTS to NUREG-1431, Revision 1; therefore, this change is not applicable to the Braidwood and Byron Station TS. 4. TS 3.1. 7, Condition A, is revised from "for one or more groups" to the more standard terminology "in one or more groups." This change does not alter the meaning. 5. TSTF-547 proposes to delete TS 3.1. 7, RA B.3, as it is redundant to RA A.1. As noted above, the Braidwood and Byron Station TS were based on NUREG-1431 Revision 1, which did not have a condition for more than one DRPI per group inoperable (i.e., no TS 3.1.7, Condition B). The new Condition Band associated RAs (as shown in TSTF-547) will be incorporated into the Braidwood and Byron Station TS; therefore, deletion of RA B.3 is not applicable.
E. Required Action and           E.1     Be in MODE 3.           6 hours associated Completion Time not met.
: 6. The existing TS 3.1.7, Condition B (renumbered as Condition C), is revised to contain similar terminology to Condition A and the new Condition B for consistency.
3.1.3   Correct Conflicts Between TS 3.1.4 and TS 3.1. 7 The current SR 3.1.4.1 states:
The current wording of the existing Condition B states, "One or more rods with inoperable DRPls have been moved in excess of 24 steps in one direction since the last determination of the rod's position." The proposed change rewords the renumbered Condition C to state: "One or more DRPls inoperable in one or more groups and associated rod has been moved >24 steps in one direction since the last position determination." This change does not alter the meaning. 7. The existing TS 3.1.7, Condition C (renumbered as Condition D), is revised from "One demand position indicator per bank inoperable for one or more banks" to "One or more demand position indicators per bank inoperable in one or more banks." The proposed change makes the terminology consistent with the Note modifying the RAs as discussed in the following paragraph.
SURVEILLANCE                                       FREQUENCY SR 3.1.4.1     Verify individual rod positions within alignment limit. In accordance with the Surveillance Frequency Control Program The SR 3.1.4.1 requires verification that individual rod positions are within the alignment limits in accordance with the surveillance frequency control program (SFCP). The proposed change is the addition of a Note to SR 3.1.4.1 stating that the SR is not required to be performed for rods associated with inoperable rod position indicator or demand position indicator. This Note is proposed to be added because SR 3. 1.4. 1 cannot be performed for rods with an inoperable demand position indicator. An editorial wording change is also proposed for SR 3.1.4.1 to make it consistent with the wording of TS 3.1. 7 RA A.1.
The current TS 3.1. 7 is modified by a Note which states, "Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator." The Bases for the Note state that the Note is acceptable because the RAs for each Condition provide appropriate compensatory actions for each inoperable indicator.
Therefore, proposed SR 3.1.4.1 would state:
There is one demand position indicator per group of rods. For banks with two groups of rods, there are two demand indicators per bank. The separate condition entry Note modifying the TS 3.1. 7 Actions states that separate condition entry is allowed for each inoperable demand position indicator which means that the renumbered Condition D is applicable to more than one inoperable demand position indicator per bank. The proposed change makes the renumbered Condition D terminology consistent with the Note. 3.2 Evaluation The NRC staff reviewed the proposed changes to the TSs and the technical justification for the changes proposed in the license amendment request (LAR) to ensure that the reasoning was logical, complete, and clearly written as described in Chapter 16 of NUREG-0800.
 
The NRC staff also reviewed the proposed changes for continued compliance with the requirements of 1 O CFR 50.36 and for consistency with conventional terminology and with the format and usage   rules embodied in the STS. In its SE for TSTF-547, Revision 1, the NRC staff did not specify any limitations or conditions for adoption of the Traveler by future applicants.
SURVEILLANCE                                                 FREQUENCY SR 3.1.4.1     - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - In accordance Not required to be performed for rods associated                       with the with inoperable rod position indicator or demand                       Surveillance position indicator.                                                   Frequency
                ------------------------------------------                             Control Program Verify position of individual rods within alignment limit.
The current SR 3.1. 7.1, states:
SURVEILLANCE                                                 FREQUENCY SR 3.1.7.1     Verify each DRPI agrees within 12 steps of the group                   Prior to criticality after demand position for the full indicated range of rod                   each removal of the travel.                                                               reactor head The LCO 3.1.4 specifies that all shutdown and control rods shall be operable and individual indicated rod positions shall be within 12 steps of their group step counter demand position.
SR 3.1. 7.1 requires verification that each DRPI agrees within the required steps of the group demand position for the full indicated range of rod travel. The proposed change is the addition of a Note to SR 3.1. 7 .1 stating that the SR would not be required to be met for rods that do not meet LCO 3.1.4.
Therefore, proposed SR 3.1.7.1 would state:
SURVEILLANCE                                                 FREQUENCY SR 3.1.7.1   - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - Prior to criticality after Not required to be met for DRPls associated with                     each removal of the rods that do not meet LCO 3.1.4.                                     reactor head
                ------------------------------------------
Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel.
3.1.4   Other Proposed Changes The proposed changes described in this section are editorial and do not change the technical content.
: 1.     TSTF-547 proposes to eliminate TS 3.1.4, Condition 8, RA 8.1, and to combine RAs 8.2.4 and 8.2.5. RA 8.1 was previously eliminated during the Braidwood and Byron Station TS transition from current technical specifications {CTS} to NUREG-1431, Revision 1. RAs 8.2.4 and 8.2.5 were previously combined in Amendment 110 (Braidwood Station) and Amendment 116 (Byron Station) (ADAMS Accession No.
ML010510325). No additional changes are necessary.
: 2.     LCO 3.1.5 and LCO 3.1.6 contain a Note modifying their Applicability that states "This LCO is not applicable while performing SR 3.1.4.2." The proposed change would revise the Notes to state: "Not applicable to shutdown banks inserted while performing SR 3.1.4.2," for LCO 3.1.5; and "Not applicable to control banks inserted while
 
performing SR 3.1.4.2," for LCO 3.1.6. This change clarifies the Note and does not alter its meaning.
: 3.       In TSTF-547, TS 3.1.7 is revised to consistently use the defined abbreviation "DRPI."
This affects the Actions Note, RA A.1, RA B.2, and RA C.1. Consistent use of the defined abbreviation "DRPI" was previously adopted during the Braidwood and Byron Station TS transition from CTS to NUREG-1431, Revision 1; therefore, this change is not applicable to the Braidwood and Byron Station TS.
: 4.     TS 3.1. 7, Condition A, is revised from "for one or more groups" to the more standard terminology "in one or more groups." This change does not alter the meaning.
: 5.       TSTF-547 proposes to delete TS 3.1. 7, RA B.3, as it is redundant to RA A.1. As noted above, the Braidwood and Byron Station TS were based on NUREG-1431 Revision 1, which did not have a condition for more than one DRPI per group inoperable (i.e., no TS 3.1.7, Condition B). The new Condition Band associated RAs (as shown in TSTF-547) will be incorporated into the Braidwood and Byron Station TS; therefore, deletion of RA B.3 is not applicable.
: 6.       The existing TS 3.1.7, Condition B (renumbered as Condition C), is revised to contain similar terminology to Condition A and the new Condition B for consistency. The current wording of the existing Condition B states, "One or more rods with inoperable DRPls have been moved in excess of 24 steps in one direction since the last determination of the rod's position." The proposed change rewords the renumbered Condition C to state:
        "One or more DRPls inoperable in one or more groups and associated rod has been moved >24 steps in one direction since the last position determination." This change does not alter the meaning.
: 7.       The existing TS 3.1.7, Condition C (renumbered as Condition D), is revised from "One demand position indicator per bank inoperable for one or more banks" to "One or more demand position indicators per bank inoperable in one or more banks." The proposed change makes the terminology consistent with the Note modifying the RAs as discussed in the following paragraph.
The current TS 3.1. 7 is modified by a Note which states, "Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator." The Bases for the Note state that the Note is acceptable because the RAs for each Condition provide appropriate compensatory actions for each inoperable indicator. There is one demand position indicator per group of rods. For banks with two groups of rods, there are two demand indicators per bank. The separate condition entry Note modifying the TS 3.1. 7 Actions states that separate condition entry is allowed for each inoperable demand position indicator which means that the renumbered Condition D is applicable to more than one inoperable demand position indicator per bank. The proposed change makes the renumbered Condition D terminology consistent with the Note.
3.2     Evaluation The NRC staff reviewed the proposed changes to the TSs and the technical justification for the changes proposed in the license amendment request (LAR) to ensure that the reasoning was logical, complete, and clearly written as described in Chapter 16 of NUREG-0800. The NRC staff also reviewed the proposed changes for continued compliance with the requirements of 1O CFR 50.36 and for consistency with conventional terminology and with the format and usage
 
rules embodied in the STS. In its SE for TSTF-547, Revision 1, the NRC staff did not specify any limitations or conditions for adoption of the Traveler by future applicants.
Although the TS bases are not part of the TS, the NRC staff confirmed that the TS bases described the basis for each revised TS requirement accurately as described in Chapter 16 of NUREG-0800.
Although the TS bases are not part of the TS, the NRC staff confirmed that the TS bases described the basis for each revised TS requirement accurately as described in Chapter 16 of NUREG-0800.
3.2.1 Provide Time to Correct Rod Movement Failures that Do Not Affect Operability The proposed new Condition A of TSs 3.1.5 and 3.1.6 for shutdown and control bank insertion limits would allow 24 hours to restore a single bank to be within its insertion limit when inserted below the insertion limit. With one shutdown or control bank inserted a maximum of 16 steps below the rod insertion limit, the RAs associated with new Condition A would also require verification that all other control and shutdown banks are within the insertion limits; and verification that the SOM is maintained or established.
3.2.1   Provide Time to Correct Rod Movement Failures that Do Not Affect Operability The proposed new Condition A of TSs 3.1.5 and 3.1.6 for shutdown and control bank insertion limits would allow 24 hours to restore a single bank to be within its insertion limit when inserted below the insertion limit. With one shutdown or control bank inserted a maximum of 16 steps below the rod insertion limit, the RAs associated with new Condition A would also require verification that all other control and shutdown banks are within the insertion limits; and verification that the SOM is maintained or established. The completion time (CT) for these RAs would be 1 hour.
The completion time (CT) for these RAs would be 1 hour. The new conditions define limits of both duration and insertion if a bank is immovable due to failures external to the CROM. A maximum of one control or shutdown bank may be inserted beyond the limits for a maximum of 24 hours provided all other banks are within the insertion limits and that the reactor could be shut down using control rods or boration.
The new conditions define limits of both duration and insertion if a bank is immovable due to failures external to the CROM. A maximum of one control or shutdown bank may be inserted beyond the limits for a maximum of 24 hours provided all other banks are within the insertion limits and that the reactor could be shut down using control rods or boration. The new Condition A imposes a limit of s 16 steps beyond the insertion limit. Given that SR 3.1.4.2 requires movement of the control and shutdown rods a minimum of 10 steps in either direction, the NRC staff asked the licensee to provide justification for the use of s 16 steps in Condition A in LCOs 3.1.5 and 3.1.6 and explain how this is consistent with that approved in the NRC staff's SE for TSTF-547. In its letter dated October 25, 2017, the licensee responded as follows:
The new Condition A imposes a limit of s 16 steps beyond the insertion limit. Given that SR 3.1.4.2 requires movement of the control and shutdown rods a minimum of 10 steps in either direction, the NRC staff asked the licensee to provide justification for the use of s 16 steps in Condition A in LCOs 3.1.5 and 3.1.6 and explain how this is consistent with that approved in the NRC staff's SE for TSTF-547.
The selection "s 16 steps" for these LCOs is consistent with the statement in the NRC's Safety Evaluation for TSTF-547 that specifies: "The value of [16] steps corresponds to the minimum number of steps that the rods must be moved to ensure correct performance of SR 3.1.4.2." The value of 16 steps is based on the design of the Digital Rod Position Indication (DRPI) System.
In its letter dated October 25, 2017, the licensee responded as follows: The selection "s 16 steps" for these LCOs is consistent with the statement in the NRC's Safety Evaluation for TSTF-547 that specifies: "The value of [16] steps corresponds to the minimum number of steps that the rods must be moved to ensure correct performance of SR 3.1.4.2." The value of 16 steps is based on the design of the Digital Rod Position Indication (DRPI) System. The licensee then went on to describe the DRPI system design. Based on the design, a light emitting diode (LED) will illuminate every 6 steps of rod movement.
The licensee then went on to describe the DRPI system design. Based on the design, a light emitting diode (LED) will illuminate every 6 steps of rod movement. Therefore, to verify 10 steps of rod movement, a change of two LEDs must be observed, i.e., the bank must be inserted 12 steps, as an insertion of only 10 steps may result in only one DRPI LED change. In addition, normal DRPI system accuracy is +/-4 steps. Therefore, the value of 16 steps corresponds to the minimum number of steps that the rods must be moved to ensure correct performance of SR 3.1.4.2. Based on the licensee's explanation, the NRC staff finds that the plant-specific value of s 16 steps is appropriate to meet the requirements of SR 3.1.4.2 and is acceptable for use in LCOs 3.1.5 and 3.1.6.
Therefore, to verify 10 steps of rod movement, a change of two LEDs must be observed, i.e., the bank must be inserted 12 steps, as an insertion of only 10 steps may result in only one DRPI LED change. In addition, normal DRPI system accuracy is +/-4 steps. Therefore, the value of 16 steps corresponds to the minimum number of steps that the rods must be moved to ensure correct performance of SR 3.1.4.2. Based on the licensee's explanation, the NRC staff finds that the plant-specific value of s 16 steps is appropriate to meet the requirements of SR 3.1.4.2 and is acceptable for use in LCOs 3.1.5 and 3.1.6. The NRC staff reviewed the justification for the proposed addition of Condition A to TS 3.1.5 and TS 3.1.6 provided in the Technical Evaluation Section of Traveler TSTF-547, to ensure that the reasoning is logical, complete, and clearly written. The justification in Traveler TSTF-547 states: 1. All control and shutdown rod assemblies are required to be Operable.
The NRC staff reviewed the justification for the proposed addition of Condition A to TS 3.1.5 and TS 3.1.6 provided in the Technical Evaluation Section of Traveler TSTF-547, to ensure that the reasoning is logical, complete, and clearly written. The justification in Traveler TSTF-547 states:
If a rod is untrippable (i.e., inoperable), then a plant shutdown is required in accordance with LCO 3.1.4, Condition A. 2. Only one control bank and shutdown bank may be inserted beyond insertion limits by no more than 16 steps. If one or more control banks or shutdown banks   exceed the insertion limit, a brief time period is permitted to correct the condition and then a plant shutdown is required.
: 1.     All control and shutdown rod assemblies are required to be Operable. If a rod is untrippable (i.e., inoperable), then a plant shutdown is required in accordance with LCO 3.1.4, Condition A.
: 3. If one rod is not within the alignment limits, adequate SDM is verified and a power reduction is required by LCO 3.1.4, Condition B. If more than one rod is not within the alignment limit as defined in LCO 3.1.4, adequate SDM is verified and a plant shutdown is required.
: 2.     Only one control bank and shutdown bank may be inserted beyond insertion limits by no more than 16 steps. If one or more control banks or shutdown banks
The insertion limits are established to ensure a sufficient amount of negative reactivity can be rapidly inserted to shut down the reactor. The NRC staff finds that allowing continued full-power operations for 24 hours with a rod movement failure is acceptable for the following reasons: 1. shutdown margin continues to be met; 2. all control and shutdown rods are trippable  
 
-i.e., capable of being rapidly inserted into the core; 3. only one bank may exceed insertion limits by no more than a specified number of steps; 4. all immovable rod assemblies are aligned; and 5. the rods must be restored to within the insertion limits within 24 hours. The change to TSs 3.1.5 and 3.1.6 to provide time to correct rod movement failures that do not affect operability will allow sufficient time for diagnosis and repairs while maintaining the safety function of the control rods since the affected rods are still trippable.
exceed the insertion limit, a brief time period is permitted to correct the condition and then a plant shutdown is required.
The thermal margins may be affected by power distribution changes due to control rod bank insertion, both during the insertion and during the resulting local xenon transient.
: 3.       If one rod is not within the alignment limits, adequate SDM is verified and a power reduction is required by LCO 3.1.4, Condition B. If more than one rod is not within the alignment limit as defined in LCO 3.1.4, adequate SDM is verified and a plant shutdown is required.
However, insertions at or near the typical value of 16 steps from fully withdrawn, as provided in the proposed changes to TSs 3.1.5 and 3.1.6, would result in a very small negative reactivity impact at the top of active fuel. The resulting effect on the axial power distribution is not expected to be significant.
The insertion limits are established to ensure a sufficient amount of negative reactivity can be rapidly inserted to shut down the reactor. The NRC staff finds that allowing continued full-power operations for 24 hours with a rod movement failure is acceptable for the following reasons:
In addition, alignment of all rods with the rod bank position (as per LCO 3.1.4) must be maintained and it will be verified that the reactor can still be shut down. Therefore, the NRC staff has determined that the proposed 24-hour CT for Condition A in TSs 3.1.5 and 3.1.6 specifying shutdown bank and control bank insertion limits is acceptable.
: 1.     shutdown margin continues to be met;
The NRC staff concludes that TS 3.1.5 and TS 3.1.6, as modified by the addition of Condition A, continue to specify the minimum performance level of equipment needed for safe operation of the facility as an LCO; and continue to specify the appropriate remedial measures if the LCO is not met. SRs are not being changed by the addition of Condition A. The NRC staff finds that the requirements of 10 CFR 50.36(c)(2) continue to be met because the minimum performance level of equipment needed for safe operation of the facility is contained in the LCO and the appropriate remedial measures are specified if the LCO is not met. 3.2.2 Provide an Alternative to Frequent Verification of Rod Position The LCO 3.1. 7 requires that the DRPI and the demand position indication system be Operable during Power Operation and Startup. When one or more DRPI per group are inoperable for one or more groups, current TS 3.1. 7 requires verification of rod position once per 8 hours using the movable incore detectors or PDMS or to reduce thermal power to less than or equal to 50 percent rated thermal power (RTP) within 8 hours. The proposed change would provide an alternative set of RAs. New RA A.2 would require the use of the movable incore detector system or PDMS to verify the position of the rod within 8 hours of the inoperability of DRPI, 8 hours after discovery of each unintended rod movement, 8 hours after each greater than 12 step movement of a rod with inoperable DRPI, prior to exceeding 50 percent RTP, 8 hours after reaching RTP, and once per 31 effective full power days thereafter.
: 2.     all control and shutdown rods are trippable - i.e., capable of being rapidly inserted into the core;
: 3.     only one bank may exceed insertion limits by no more than a specified number of steps;
: 4.     all immovable rod assemblies are aligned; and
: 5.     the rods must be restored to within the insertion limits within 24 hours.
The change to TSs 3.1.5 and 3.1.6 to provide time to correct rod movement failures that do not affect operability will allow sufficient time for diagnosis and repairs while maintaining the safety function of the control rods since the affected rods are still trippable. The thermal margins may be affected by power distribution changes due to control rod bank insertion, both during the insertion and during the resulting local xenon transient. However, insertions at or near the typical value of 16 steps from fully withdrawn, as provided in the proposed changes to TSs 3.1.5 and 3.1.6, would result in a very small negative reactivity impact at the top of active fuel. The resulting effect on the axial power distribution is not expected to be significant. In addition, alignment of all rods with the rod bank position (as per LCO 3.1.4) must be maintained and it will be verified that the reactor can still be shut down. Therefore, the NRC staff has determined that the proposed 24-hour CT for Condition A in TSs 3.1.5 and 3.1.6 specifying shutdown bank and control bank insertion limits is acceptable.
The NRC staff concludes that TS 3.1.5 and TS 3.1.6, as modified by the addition of Condition A, continue to specify the minimum performance level of equipment needed for safe operation of the facility as an LCO; and continue to specify the appropriate remedial measures if the LCO is not met. SRs are not being changed by the addition of Condition A. The NRC staff finds that the requirements of 10 CFR 50.36(c)(2) continue to be met because the minimum performance level of equipment needed for safe operation of the facility is contained in the LCO and the appropriate remedial measures are specified if the LCO is not met.
3.2.2   Provide an Alternative to Frequent Verification of Rod Position The LCO 3.1. 7 requires that the DRPI and the demand position indication system be Operable during Power Operation and Startup. When one or more DRPI per group are inoperable for one or more groups, current TS 3.1. 7 requires verification of rod position once per 8 hours using the movable incore detectors or PDMS or to reduce thermal power to less than or equal to 50 percent rated thermal power (RTP) within 8 hours. The proposed change would provide an alternative set of RAs.
 
New RA A.2 would require the use of the movable incore detector system or PDMS to verify the position of the rod within 8 hours of the inoperability of DRPI, 8 hours after discovery of each unintended rod movement, 8 hours after each greater than 12 step movement of a rod with inoperable DRPI, prior to exceeding 50 percent RTP, 8 hours after reaching RTP, and once per 31 effective full power days thereafter.
TSTF-547 proposed a new RA A.2.2 that would require the inoperable DRPI to be restored to operable status prior to entering startup (MODE 2) from hot standby (MODE 3). In its letter dated May 29, 2018, the licensee requested to not include this RA. The licensee provided justification that showed that this RA would never be limiting or implemented because the RAs are joined by a logical "OR," any one of the RAs may be chosen. In addition, when an LCO is not met, LCO 3.0.4.a allows entry into a MODE in which an LCO is applicable when the associated actions to be entered permit continued operation in the MODE for an unlimited period of time. Since the LCO permits continued operation with the specified RAs, entering startup from hot standby is allowed. Based on the above, the NRC staff determined that not including a new RA A.2.2 is appropriate because it is unnecessary and could cause confusion.
TSTF-547 proposed a new RA A.2.2 that would require the inoperable DRPI to be restored to operable status prior to entering startup (MODE 2) from hot standby (MODE 3). In its letter dated May 29, 2018, the licensee requested to not include this RA. The licensee provided justification that showed that this RA would never be limiting or implemented because the RAs are joined by a logical "OR," any one of the RAs may be chosen. In addition, when an LCO is not met, LCO 3.0.4.a allows entry into a MODE in which an LCO is applicable when the associated actions to be entered permit continued operation in the MODE for an unlimited period of time. Since the LCO permits continued operation with the specified RAs, entering startup from hot standby is allowed. Based on the above, the NRC staff determined that not including a new RA A.2.2 is appropriate because it is unnecessary and could cause confusion.
The implementation of new RA A.2 would allow the use of an alternative monitoring scheme. This alternative method reduces potential wear on the movable incore detector system when PDMS is inoperable and also reduces the time required to perform the frequent rod position verifications.
The implementation of new RA A.2 would allow the use of an alternative monitoring scheme.
The NRC staff finds that the new RA A.2 and CT is appropriate because it requires verification of rod position following circumstances in which rod motion could occur. This is a more tailored approach than current TS 3.1. 7 RA A.1, which requires verification of rod position using the moveable incore detector system or PDMS once per 8 hours, regardless of whether the rods have moved. If the rod position indication is failed for an individual rod, its position is determined indirectly by the use of the moveable incore detectors or PDMS. The NRC staff has determined that this change, which verifies rod position based on the occurrence of events requiring rod motion, rather than determining position on a specified frequency, is acceptable because events requiring rod motion of the shutdown banks and control banks A, B, and C are relatively infrequent during steady state operation.
This alternative method reduces potential wear on the movable incore detector system when PDMS is inoperable and also reduces the time required to perform the frequent rod position verifications. The NRC staff finds that the new RA A.2 and CT is appropriate because it requires verification of rod position following circumstances in which rod motion could occur.
Events involving significant movement of rods in control bank D are also relatively infrequent.
This is a more tailored approach than current TS 3.1. 7 RA A.1, which requires verification of rod position using the moveable incore detector system or PDMS once per 8 hours, regardless of whether the rods have moved.
The indirect determination of rod position is required after significant changes in power level or following substantial rod motion. The addition of the Note to SR 3.1.4.1 stating that the SR is not required to be performed for rods associated with an inoperable rod position indicator or demand position indicator is appropriate because the RAs of TS 3.1. 7 for an inoperable DRPI provide the appropriate actions for indirectly determining the position of the affected rods. The NRC staff concludes that the addition of an alternative monitoring scheme to indirectly determine the position of rods associated with an inoperable DRPI is acceptable.
If the rod position indication is failed for an individual rod, its position is determined indirectly by the use of the moveable incore detectors or PDMS. The NRC staff has determined that this change, which verifies rod position based on the occurrence of events requiring rod motion, rather than determining position on a specified frequency, is acceptable because events requiring rod motion of the shutdown banks and control banks A, B, and C are relatively infrequent during steady state operation. Events involving significant movement of rods in control bank D are also relatively infrequent. The indirect determination of rod position is required after significant changes in power level or following substantial rod motion.
TS 3.1. 7, as modified, continues to specify the minimum performance level of equipment needed for safe operation of the facility as an LCO and continues to specify the appropriate remedial measures if the LCO is not met. The revised SR 3.1.4.1, which has been clarified to specify when it is required to be performed, continues to be an appropriate test to ensure that the necessary quality of systems is maintained.
The addition of the Note to SR 3.1.4.1 stating that the SR is not required to be performed for rods associated with an inoperable rod position indicator or demand position indicator is appropriate because the RAs of TS 3.1. 7 for an inoperable DRPI provide the appropriate actions for indirectly determining the position of the affected rods.
The NRC staff finds that the requirements of 10 CFR 50.36(c)(2) continue to be met because the minimum performance level of equipment needed for safe operation of the facility is contained in the LCO and the appropriate remedial measures are specified if the LCO is not met. The NRC staff finds that the requirements of 10 CFR 50.36(c)(3) continue to be met because the revised SR provides the appropriate testing to ensure the necessary quality of components is maintained and that the LCO will be met. 3.2.3 Correct Conflicts Between TS 3.1.4 and TS 3.1. 7 The LCO 3.1.4 requires that all shutdown and control rods shall be operable and individual indicated rod positions shall be within 12 steps of their group step counter demand position.
The NRC staff concludes that the addition of an alternative monitoring scheme to indirectly determine the position of rods associated with an inoperable DRPI is acceptable. TS 3.1. 7, as modified, continues to specify the minimum performance level of equipment needed for safe operation of the facility as an LCO and continues to specify the appropriate remedial measures if the LCO is not met. The revised SR 3.1.4.1, which has been clarified to specify when it is required to be performed, continues to be an appropriate test to ensure that the necessary quality of systems is maintained. The NRC staff finds that the requirements of 10 CFR 50.36(c)(2) continue to be met because the minimum performance level of equipment needed for safe operation of the facility is contained in the LCO and the appropriate remedial measures are specified if the LCO is not met. The NRC staff finds that the requirements of 10 CFR 50.36(c)(3) continue to be met because the revised SR provides the appropriate testing to ensure the necessary quality of components is maintained and that the LCO will be met.
SR 3.1.4.1 requires verification of the individual rod positions within the alignment limit periodically.
 
SR 3.1.4.1 cannot be performed for rods with an inoperable bank demand position indicator.
3.2.3   Correct Conflicts Between TS 3.1.4 and TS 3.1. 7 The LCO 3.1.4 requires that all shutdown and control rods shall be operable and individual indicated rod positions shall be within 12 steps of their group step counter demand position.
Failure to meet an SR is considered a failure to meet an LCO requirement.
SR 3.1.4.1 requires verification of the individual rod positions within the alignment limit periodically. SR 3.1.4.1 cannot be performed for rods with an inoperable bank demand position indicator. Failure to meet an SR is considered a failure to meet an LCO requirement.
Therefore, if SR 3.1.4.1 cannot be performed, entry into LCO 3.1.4 Condition C is required.
Therefore, if SR 3.1.4.1 cannot be performed, entry into LCO 3.1.4 Condition C is required.
LCO 3.1.4, Condition C, applies when more than one rod is not within the alignment limit. The RA associated with Condition C requires, in part, that the reactor be in hot standby within 6 hours. LCO 3.1. 7 requires the DRPI system and the demand position indication system to be operable.
LCO 3.1.4, Condition C, applies when more than one rod is not within the alignment limit. The RA associated with Condition C requires, in part, that the reactor be in hot standby within 6 hours.
Current LCO 3.1. 7, Condition C, applies if one indicator per bank is inoperable for one or more banks. The Condition C RAs require verification that all DRPls for the affected banks are operable and require verification that the most withdrawn rod and least withdrawn rod of the affected banks are less than or equal to 12 steps apart once per 8 hours. Alternatively, thermal power must be reduced to less than or equal to 50 percent RTP. A Note would be added to SR 3.1.4.1 stating that this SR is not required to be performed for rods associated with an inoperable rod position indicator or demand position indicator.
LCO 3.1. 7 requires the DRPI system and the demand position indication system to be operable.
The alignment limit is based on the demand position indicator.
Current LCO 3.1. 7, Condition C, applies if one indicator per bank is inoperable for one or more banks. The Condition C RAs require verification that all DRPls for the affected banks are operable and require verification that the most withdrawn rod and least withdrawn rod of the affected banks are less than or equal to 12 steps apart once per 8 hours. Alternatively, thermal power must be reduced to less than or equal to 50 percent RTP.
If the bank demand position indicator is inoperable, the SR cannot be performed.
A Note would be added to SR 3.1.4.1 stating that this SR is not required to be performed for rods associated with an inoperable rod position indicator or demand position indicator. The alignment limit is based on the demand position indicator. If the bank demand position indicator is inoperable, the SR cannot be performed.
Following the proposed modification of SR 3.1.4.1, Condition D (renumbered current Condition C) of LCO 3.1.7 would be the applicable condition to be entered in the event of inoperable demand position indicators.
Following the proposed modification of SR 3.1.4.1, Condition D (renumbered current Condition C) of LCO 3.1.7 would be the applicable condition to be entered in the event of inoperable demand position indicators. The RAs associated with Condition D of LCO 3.1. 7 provide the appropriate actions in this situation by requiring that the DRPls are operable and that the individual rods in the bank are not misaligned by more than 12 steps.
The RAs associated with Condition D of LCO 3.1. 7 provide the appropriate actions in this situation by requiring that the DRPls are operable and that the individual rods in the bank are not misaligned by more than 12 steps. The SR 3.1. 7 .1 requires verification that each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel. This SR is performed once prior to criticality after each removal of the reactor head. Failure to meet an SR is considered a failure to meet the LCO per SR 3.0.1. The requirements of SRs must be satisfied in between performances of the surveillance test itself. Therefore, if a control or shutdown rod is not within 12 steps of its bank demand position indication, then the requirements of both LCO 3.1.4 and LCO 3.1. 7 are not met. A Note would be added to SR 3.1. 7 .1 stating that this SR is not required to be met for DRPls associated with rods that do not to meet LCO 3.1.4. If a rod is known not to be within 12 steps of the group demand position, LCO 3.1.4 provides the appropriate RAs. With one rod not within the alignment limit, Condition B requires verification of shutdown margin or boration until SDM is met, reduction in RTP, verification of shutdown margin once per 12 hours, verification of hot channel factors within limits, and reevaluation of safety analyses and confirming that continued operation is permissible.
The SR 3.1. 7 .1 requires verification that each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel. This SR is performed once prior to criticality after each removal of the reactor head. Failure to meet an SR is considered a failure to meet the LCO per SR 3.0.1. The requirements of SRs must be satisfied in between performances of the surveillance test itself. Therefore, if a control or shutdown rod is not within 12 steps of its bank demand position indication, then the requirements of both LCO 3.1.4 and LCO 3.1. 7 are not met.
If more than one rod is misaligned, the SDM must be verified to be within limits or boration must be initiated to restore required SDM, and the plant must be shut down. The NRC staff reviewed the technical justification for the proposed changes provided in the LAR and TSTF-547 for logical reasoning, completeness, and clarity. The purpose of the changes is to prescribe the appropriate Actions to be followed when equipment is inoperable. The TS 3.1.4 provides limits on rod alignment to ensure acceptable power peaking factors and local linear heat rates and an acceptable shutdown margin, all of which are initial conditions in the applicable safety analyses.
A Note would be added to SR 3.1. 7 .1 stating that this SR is not required to be met for DRPls associated with rods that do not to meet LCO 3.1.4. If a rod is known not to be within 12 steps of the group demand position, LCO 3.1.4 provides the appropriate RAs. With one rod not within the alignment limit, Condition B requires verification of shutdown margin or boration until SDM is met, reduction in RTP, verification of shutdown margin once per 12 hours, verification of hot channel factors within limits, and reevaluation of safety analyses and confirming that continued operation is permissible. If more than one rod is misaligned, the SDM must be verified to be within limits or boration must be initiated to restore required SDM, and the plant must be shut down.
It is appropriate to consolidate requirements associated with rod misalignments in this TS. TS 3.1. 7 provides requirements for instrumentation to monitor rod position.
The NRC staff reviewed the technical justification for the proposed changes provided in the LAR and TSTF-547 for logical reasoning, completeness, and clarity. The purpose of the changes is to prescribe the appropriate Actions to be followed when equipment is inoperable.
The instrumentation is used to verify that the rod alignment limits in TS 3.1.4 are satisfied.
 
Similarly, it is appropriate to consolidate requirements associated with instrumentation operability in this TS. The NRC staff concludes that the clarification notes to SRs 3.1.4.1 and 3.1.7.1 to specify configurations in which performance of the SRs is not required are appropriate.
The TS 3.1.4 provides limits on rod alignment to ensure acceptable power peaking factors and local linear heat rates and an acceptable shutdown margin, all of which are initial conditions in the applicable safety analyses. It is appropriate to consolidate requirements associated with rod misalignments in this TS. TS 3.1. 7 provides requirements for instrumentation to monitor rod position. The instrumentation is used to verify that the rod alignment limits in TS 3.1.4 are satisfied. Similarly, it is appropriate to consolidate requirements associated with instrumentation operability in this TS.
The TSs, as modified, continue to specify the minimum performance level of equipment needed for safe operation of the facility as an LCO, and continue to specify the appropriate remedial measures if the LCO is not met. The revised SRs 3.1.4.1 and 3.1.7.1 continue to be appropriate, because they ensure the necessary quality of systems is maintained and that the LCOs will be met. Based on the above, the NRC staff finds that the requirements of 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3) continue to be met. 3.2.4 Other Proposed Changes The changes described above in Section 3.1.4 were proposed to improve the presentation of the requirements or are administrative in nature. The LCOs 3.1.5 and 3.1.6 contain a Note modifying their Applicability that states: "This LCO is not applicable while performing SR 3.1.4.2." The proposed change would revise the Notes to state: "Not applicable to shutdown banks inserted while performing SR 3.1.4.2," for LCO 3.1.5 and "Not applicable to control banks inserted while performing SR 3.1.4.2," for LCO 3.1.6. The NRC staff finds that this change is administrative in nature and does not alter the Note's meaning. TS 3.1.7, Condition A, would be revised from "for one or more groups" to the more standard terminology "in one or more groups." The NRC staff finds that this change is administrative in nature and does not alter the condition's meaning. The existing TS 3.1.7, Condition B (renumbered as Condition C), is revised to contain similar terminology to Condition A and the new Condition B for consistency.
The NRC staff concludes that the clarification notes to SRs 3.1.4.1 and 3.1.7.1 to specify configurations in which performance of the SRs is not required are appropriate. The TSs, as modified, continue to specify the minimum performance level of equipment needed for safe operation of the facility as an LCO, and continue to specify the appropriate remedial measures if the LCO is not met. The revised SRs 3.1.4.1 and 3.1.7.1 continue to be appropriate, because they ensure the necessary quality of systems is maintained and that the LCOs will be met.
The current wording of the existing Condition B states, "One or more rods with inoperable DRPls have been moved in excess of 24 steps in one direction since the last determination of the rod's position." The proposed change rewords the renumbered Condition C to state, "One or more DRPls inoperable in one or more groups and associated rod has been moved > 24 steps in one direction since the last position determination." The NRC Staff finds that this change is administrative in nature and does not alter the condition's meaning. The existing TS 3.1.7, Condition C (renumbered as Condition D), is revised from "One demand position indicator per bank inoperable for one or more banks" to "One or more demand position indicators per bank inoperable in one or more banks." The NRC staff finds that this change makes the.terminology consistent with the Note modifying the RAs and that this change is administrative in nature and does not alter the condition's meaning. There were several items noted in the LAR which state that TSTF-547 changes are not being applied as they are not applicable.
Based on the above, the NRC staff finds that the requirements of 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3) continue to be met.
This is due to TSTF-547 being based on NUREG-1431, Revision 4, while Braidwood and Byron Station TS are based on Revision 1. As an example, TSTF-547 deletes TS 3.1.7, Required Action 8.2, "Monitor and record Reactor Coolant System   Tavg." The Braidwood and Byron Station TS do not have the subject Condition 8, so deletion of the associated RA B.2 is not applicable.
3.2.4   Other Proposed Changes The changes described above in Section 3.1.4 were proposed to improve the presentation of the requirements or are administrative in nature.
Note that EGC did not request adopting TSTF-547 verbiage in its entirety due to variations from TSTF-547 that already exist in the current Braidwood Station and Byron Station TS. Therefore, the NRC staff reviewed only the proposed changes and did not review TSTF-547 modifications that were not proposed.
The LCOs 3.1.5 and 3.1.6 contain a Note modifying their Applicability that states: "This LCO is not applicable while performing SR 3.1.4.2." The proposed change would revise the Notes to state: "Not applicable to shutdown banks inserted while performing SR 3.1.4.2," for LCO 3.1.5 and "Not applicable to control banks inserted while performing SR 3.1.4.2," for LCO 3.1.6. The NRC staff finds that this change is administrative in nature and does not alter the Note's meaning.
3.3 Summary of NRC Staff Conclusions The regulations at 10 CFR 50.36 require that TSs include items in specified categories, including LCOs and SRs. The proposed changes would modify the LCOs, Conditions, RAs, CTs, and SRs applicable to control rod and shutdown rod insertion and alignment limits and the instrumentation to monitor rod position and alignment.
TS 3.1.7, Condition A, would be revised from "for one or more groups" to the more standard terminology "in one or more groups." The NRC staff finds that this change is administrative in nature and does not alter the condition's meaning.
The TSs would continue to specify the LCOs and specify the remedial measures to be taken if one of these requirements is not satisfied.
The existing TS 3.1.7, Condition B (renumbered as Condition C), is revised to contain similar terminology to Condition A and the new Condition B for consistency. The current wording of the existing Condition B states, "One or more rods with inoperable DRPls have been moved in excess of 24 steps in one direction since the last determination of the rod's position." The proposed change rewords the renumbered Condition C to state, "One or more DRPls inoperable in one or more groups and associated rod has been moved > 24 steps in one direction since the last position determination." The NRC Staff finds that this change is administrative in nature and does not alter the condition's meaning.
The TSs would continue to specify the appropriate SRs for tests and inspections to ensure the necessary quality of affected structures, systems, and components is maintained and that the LCOs will be met. Based on the above, the NRC staff concludes that the proposed LCOs and SRs meet the requirements of 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3), respectively, and are, therefore, acceptable.  
The existing TS 3.1.7, Condition C (renumbered as Condition D), is revised from "One demand position indicator per bank inoperable for one or more banks" to "One or more demand position indicators per bank inoperable in one or more banks." The NRC staff finds that this change makes the.terminology consistent with the Note modifying the RAs and that this change is administrative in nature and does not alter the condition's meaning.
There were several items noted in the LAR which state that TSTF-547 changes are not being applied as they are not applicable. This is due to TSTF-547 being based on NUREG-1431, Revision 4, while Braidwood and Byron Station TS are based on Revision 1. As an example, TSTF-547 deletes TS 3.1.7, Required Action 8.2, "Monitor and record Reactor Coolant System
 
Tavg." The Braidwood and Byron Station TS do not have the subject Condition 8, so deletion of the associated RA B.2 is not applicable. Note that EGC did not request adopting TSTF-547 verbiage in its entirety due to variations from TSTF-547 that already exist in the current Braidwood Station and Byron Station TS. Therefore, the NRC staff reviewed only the proposed changes and did not review TSTF-547 modifications that were not proposed.
3.3     Summary of NRC Staff Conclusions The regulations at 10 CFR 50.36 require that TSs include items in specified categories, including LCOs and SRs. The proposed changes would modify the LCOs, Conditions, RAs, CTs, and SRs applicable to control rod and shutdown rod insertion and alignment limits and the instrumentation to monitor rod position and alignment. The TSs would continue to specify the LCOs and specify the remedial measures to be taken if one of these requirements is not satisfied. The TSs would continue to specify the appropriate SRs for tests and inspections to ensure the necessary quality of affected structures, systems, and components is maintained and that the LCOs will be met. Based on the above, the NRC staff concludes that the proposed LCOs and SRs meet the requirements of 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3),
respectively, and are, therefore, acceptable.


==4.0 STATE CONSULTATION==
==4.0     STATE CONSULTATION==


In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendments on March 1, 2018. The State official had no comments.
In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendments on March 1, 2018. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements.
The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission previously issued a proposed finding on August 29, 2017 (82 FR 41069), that the amendments involve no significant hazards consideration, and there has been no public comment on such finding. The supplements dated October 25, 2017 and May 29, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination.
Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR Section 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.


==6.0 CONCLUSION==
==5.0      ENVIRONMENTAL CONSIDERATION==
 
The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission previously issued a proposed finding on August 29, 2017 (82 FR 41069), that the amendments involve no significant hazards consideration, and there has been no public comment on such finding. The supplements dated October 25, 2017 and May 29, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination.
Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR Section 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
 
==6.0     CONCLUSION==
 
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the
 
amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: R. Beaton Date of issuance: June 2 7 ,    2018


The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the  amendments will not be inimical to the common defense and security or to the health and safety of the public. Principal Contributor:
B. Hanson                              
R. Beaton Date of issuance:
June 2 7 , 2 0 1 8 B. Hanson  


==SUBJECT:==
==SUBJECT:==
BRAIDWOOD STATION, UNITS 1 AND 2, AND BYRON STATION, UNIT NOS. 1 AND 2 -ISSUANCE OF AMENDMENTS REGARDING CLARIFICATION OF ROD POSITION REQUIREMENTS (CAC NOS. MF9951, MF9952, MF9953, AND MF9954; EPID L-2017-LLA-0249)
BRAIDWOOD STATION, UNITS 1 AND 2, AND BYRON STATION, UNIT NOS.
DATED JUNE 27, 2018 DISTRIBUTION:
1 AND 2 - ISSUANCE OF AMENDMENTS REGARDING CLARIFICATION OF ROD POSITION REQUIREMENTS (CAC NOS. MF9951, MF9952, MF9953, AND MF9954; EPID L-2017-LLA-0249) DATED JUNE 27, 2018 DISTRIBUTION:
PUBLIC RidsNrrDirsltsb Resource RidsRgn3MailCenter Resource RidsNrrDorllpl3 Resource RidsNrrLASRohrer Resource RidsNrrPMByron Resource RidsNrrDorlDpr Resource RidsNrrPMBraidwood Resource RidsACRS_MailCTR Resource Accession No. ML18065A529 OFFICE DORL/LPL3/PM NAME JWiebe DATE 6/4/18 OFFICE STSB/BC NAME VCusumano DATE 6/6/18 *via memo **via e-mail DORL/LPL3/LA SRXB/BC(A)
PUBLIC RidsNrrDirsltsb Resource RidsRgn3MailCenter Resource RidsNrrDorllpl3 Resource RidsNrrLASRohrer Resource RidsNrrPMByron Resource RidsNrrDorlDpr Resource RidsNrrPMBraidwood Resource RidsACRS_MailCTR Resource Accession No. ML18065A529                                   *via memo **via e-mail OFFICE        DORL/LPL3/PM      DORL/LPL3/LA     SRXB/BC(A)       SNPB/BC NAME          JWiebe            SRohrer           JWhitman*       Rlukes*
SNPB/BC SRohrer JWhitman*
DATE          6/4/18            3/7/18           2/8/18           2/8/18 OFFICE        STSB/BC          OGC**             DORL/LPL3/BC     DORL/LPL3/PM NAME          VCusumano        JLW NLO           DWrona           JWiebe DATE          6/6/18            6/12/18           6/27/18         6/27/18 OFFICIAL RECORD COPY}}
Rlukes* 3/7/18 2/8/18 2/8/18 OGC** DORL/LPL3/BC DORL/LPL3/PM JLW NLO DWrona JWiebe 6/12/18 6/27/18 6/27/18 OFFICIAL RECORD COPY}}

Revision as of 18:02, 21 October 2019

Issuance of Amendments Regarding Clarification of Rod Position Requirements (CAC Nos. MF9951-9954; EPID L-2017-LLA-0249)
ML18065A529
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 06/27/2018
From: Joel Wiebe
Plant Licensing Branch III
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
Wiebe J
References
CAC MF9951, CAC MF9952, CAC MF9953, CAC MF9954, EPID L-2017-LLA-0249
Download: ML18065A529 (58)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 27, 2018 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)

Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2, AND BYRON STATION, UNIT NOS.

1 AND 2- ISSUANCE OF AMENDMENTS REGARDING CLARIFICATION OF ROD POSITION REQUIREMENTS (CAC NOS. MF9951, MF9952, MF9953, AND MF9954; EPID L-2017-LLA-0249)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 196 to Renewed Facility Operating License No. NPF-72 and Amendment No.

196 to Renewed Facility Operating License No. NPF-77 for the Braidwood Station, Units 1 and 2, respectively, and Amendment No. 202 to Renewed Facility Operating License No. NPF-37 and Amendment No. 202 to Renewed Facility Operating License No. NPF-66 for the Byron Station, Unit Nos. 1 and 2, respectively. The amendments are in response to your application dated June 30, 2017 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML17187A191 ), as supplemented by letters dated October 25, 2017 (ADAMS Accession No. ML172986536) and May 29, 2018 (ADAMS Accession No. ML18149A637}.

B. Hanson A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

~~:1-Joel S. Wiebe, Senior Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454, and STN 50-455

Enclosures:

1. Amendment No. 196 to NPF-72
2. Amendment No. 196 to NPF-77
3. Amendment No. 202 to NPF-37
4. Amendment No. 202 to NPF-66
5. Safety Evaluation cc w/enclosures: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-456 BRAIDWOOD STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 196 Renewed License No. NPF-72

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 30, 2017, as supplemented by letters dated October 25, 2017 and May 29, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2} of Renewed Facility Operating License No. NPF-72 is hereby amended to read as follows:

Enclosure 1

(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 196 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

()J 9 cf~

David J. Wrona, Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: June 2 7 , 2 O1 8

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-457 BRAIDWOOD STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 196 Renewed License No. NPF-77

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 30, 2017, as supplemented by letters dated October 25, 2017 and May 29, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;

8. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-77 is hereby amended to read as follows:

Enclosure 2

(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 196 and the Environmental Protection Plan contained in Appendix B, both of which are attached to Renewed License No. NPF-72, dated January 27, 2016, are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date if its issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

()JO<\(_

David J. Wron/~hief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: June 2 7 , 2 O1 8

ATTACHMENT TO LICENSE AMENDMENT NOS. 196 AND 196 RENEWED FACILITY OPERATING LICENSE NOS. NPF-72 AND NPF-77 BRAIDWOOD STATION, UNITS 1 AND 2 DOCKET NOS. STN 50-456 AND STN 50-457 Replace the following pages of the Renewed Facility Operating Licenses and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove License NPF-72 License NPF-72 Page 3 Page 3 License NPF-77 License NPF-77 Page 3 Page 3 TSs TSs 3.1.4-4 3.1.4-4 3.1.5-1 3.1.5-1 3.1.5-2 3.1.5-2 3.1.6-1 3.1.6-1 3.1.6-2 3.1.6-2 3.1.6-3 3.1.6-3 3.1.7-1 3.1.7-1 3.1.7-2 3.1.7-2 3.1.7-3 3.1.7-4

(2) Exelon Generation Company, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (3) Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

( 1) Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of 3645 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 196 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Renewed License No. NPF-72 Amendment No. 196

(2) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (3) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of 3645 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 196 and the Environmental Protection Plan contained in Appendix B, both of which are attached to Renewed License No. NPF-72, dated January 27, 2016, are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Renewed License No. NPF-77 Amendment No. 196

Rod Group Alignment Limits 3.1.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition B or Required Action C.3 not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 -------------------NOTE--------------------

Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.

Verify pQsition of individual rods within In accordance al i gnment l i mi t. with the Surveillance Frequency Control Program SR 3.1.4.2 Verify rod freedom of movement In accordance (trippability) by moving each rod not fully with the inserted in the core~ 10 steps in either Surveillance direction. Frequency Control Program SR 3.1.4.3 Verify rod drop time of each rod, from the Prior to fully withdrawn position, is~ 2.7 seconds criticality from the beginning of decay of stationary after each gripper coil voltage to dashpot entry, removal of the with: reactor head

a. Tavg ~ 550°F; and
b. All reactor coolant pumps operating.

BRAIDWOOD - UNITS 1 &2 3.1.4 - 4 Amendment 196

Shutdown Bank Insertion Limits 3.1.5 3.1 REACTIVITY CONTROL SYSTEMS 3.1.5 Shutdown Bank Insertion Limits LCD 3.1. 5 Each shutdown bank shall be within the insertion limits specified in the COLR.

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

Not applicable to shutdown banks inserted while performing SR 3.1.4.2.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One shutdown bank A.l Verify all control 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inserted~ 16 steps banks are within the beyond the insertion insertion limits limits specified in specified in the the COLR. COLR.

AND A. 2.1 Verify SOM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the limits specified in the COLR.

OR A.2.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SOM to within limit.

A. 3 Restore the shutdown 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> bank to within the insertion limits specified in the COLR.

(continued)

BRAIDWOOD - UNITS 1 &2 3.1.5-1 Amendment 196

Shutdown Bank Insertion Limits 3.1.5 ACTIONS (continued)

CONDITION REQU I RED ACTION COMPLETION TIME B. One or more shutdown B.1.1 Verify SDM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> banks not within the limits specified limits for reasons in the COLR.

other than Condition A. OR B.1.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SDM to within 1imi t.

AND B.2 Restore shutdown 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> bank(s) to within 1imits.

C. Required Action and C.l Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify each shutdown bank is within the In accordance insertion limits specified in the COLR. with the Surveillance Frequency Control Program BRAIDWOOD - UNITS 1 &2 3.1.5-2 Amendment 196

Control Bank Insertion Limits 3.1.6 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 Control Bank Insertion Limits LCD 3.1.6 Each control bank shall be within the insertion, sequence, and overlap limits specified in the COLR.

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

Not applicable to control banks inserted while performing SR 3.1.4.2.

APPLICABILITY: MODE 1, MODE 2 with keff ~ 1. 0.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Control bank A, B or C A.l. Verify all shutdown 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inserted~ 16 steps banks are within the beyond the insertion, insertion limits sequence, or overlap specified in the limits specified in COLR.

the COLR.

AND A.2.1 Verify SOM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the limits specified in the COLR.

A.2.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SOM to within limit.

AND A.3 Restore the control 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> bank to within the insertion, sequence, and overlap limits specified in the COLR.

(continued)

BRAIDWOOD - UNITS 1 &2 3.1.6-1 Amendment 196

Control Bank Insertion Limits 3.1.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Control bank insertion B.1.1 Verify SDM i's within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> limits not met for the limits specified reasons other than in the COLR.

Condition A.

OR B.1.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SDM to within limit.

AND B.2 Restore control 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> bank(s) to within limits.

C. Control bank sequence C.1.1 Verify SDM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or overlap limits not the limits specified met for reasons other in the COLR.

than Condition A.

OR C.1.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SDM to within limit.

AND C.2 Restore control bank 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> sequence and overlap to within limits.

D. Required Action and D.l Be in MODE 2 with 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion kett < 1.0.

Time not met.

BRAIDWOOD - UNITS 1 &2 3.1.6 - 2 Amendment 196

Control Bank Insertion Limits 3.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 Verify estimated critical control bank Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> position is within the limits specified in prior to the COLR. criticality SR 3.1.6.2 Verify each control bank is within the In accordance insertion limits specified in the COLR. with the Surveillance Frequency Control Program SR 3.1.6.3 Verify each control bank not fully In accordance withdrawn from the core is within the with the sequence and overlap limits specified in Surveillance the COLR. Frequency Control Program BRAIDWOOD - UNITS 1 &2 3.1.6-3 Amendment 196

Rod Position Indication 3.1. 7 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Rod Position Indication LCO 3.1.7 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

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

Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.

CONDITION REQUIRED ACTION COMPLETION TIME A. One DRPI per group A.l Verify the position Once per 8 hours inoperable in one or of the rods with more groups. inoperable DRPis.

OR A.2 Verify the position 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the rods with inoperable DRPis. AND Once per 31 EFPD thereafter 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after discovery of each unintended rod movement (continued)

BRAIDWOOD - UNITS 1 &2 3.1.7-1 Amendment 196

Rod Position Indication 3.1. 7 CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after each movement of rod with inoperable DRPI

> 12 steps AND Prior to THERMAL POWER exceeding 50% RTP AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after reaching RTP OR A.3 Reduce THERMAL POWER 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> TO ~ 50% RTP.

B. More than one DRPI per B.1 Place the control Imnediately group inoperable in rods under manual one or more groups. control.

AND B.2 Restore inoperable 24 Hours DRPis to OPERABLE status such that a maximum of one DRPI per grou~ is inoperab e.

(continued)

BRAIDWOOD - UNITS 1 &2 3.1.7-2 Amendment 196

Rod Position Indication 3.1. 7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more DRPis C.l Initiate action to Inmediately inoperable in one or verify the position more groups and of the rods with associated rod has inoperable DRPis.

been moved> 24 steps in one direction since OR the last determination of the rod's position. C.2 Reduce THERMAL POWER 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to s 50% RTP.

D. One or more demand 0.1.1 Verify by Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> position indicators administrative means per bank inoperable all DRPis for the in one or more banks. affected bank(s) are OPERABLE.

AND 0.1.2 Verify the most Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> withdrawn rod and the least withdrawn rod of the affected bank(s) are s 12 steps apart.

OR 0.2 Reduce THERMAL POWER 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to s 50% RTP.

E. Required Action and E.l Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

BRAIDWOOD - UNITS 1 &2 3.1.7-3

  • Amendment 196

Rod Position Indication 3.1. 7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 -------------------NOTE-------------------- Prior to Not required to be met for DRPis associated criticality with rods that do not meet LCD 3.1.4. after each removal of the reactor head Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel.

BRAIDWOOD - UNITS 1 &2 3.1.7-4 Amendment 196

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-454 BYRON STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 202 Renewed License No. NPF-37

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 30, 2017, as supplemented by letters dated October 25, 2017 and May 29, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-37 is hereby amended to read as follows:

Enclosure 3

(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 202 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION C)__j, 1 0 4-J'~

David J. Wronl.Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: June 2 7, 2 O1 8

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-455 BYRON STATION, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 202 Renewed License No. NPF-66

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 30, 2017, as supplemented by letters dated October 25, 2017 and May 29, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 1O CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-66 is hereby amended to read as follows:

Enclosure 4

(2) Technical Specifications The Technical Specifications contained in Appendix A (NUREG-1113), as revised through Amendment No. 202 and the Environmental Protection Plan contained in Appendix B, both of which were attached to Renewed License No. NPF-37, dated November 19, 2015, are hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

()~; q !Y'~

David J. Wrona, Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: June 2 7, 2 O1 8

ATTACHMENT TO LICENSE AMENDMENT NOS. 202 AND 202 RENEWED FACILITY OPERATING LICENSE NOS. NPF-37 AND NPF-66 BYRON STATION, UNIT NOS. 1 AND 2 DOCKET NOS. STN 50-454 AND STN 50-455 Replace the following pages of the Renewed Facility Operating Licenses and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert License NPF-37 License NPF-37 Page 3 Page 3 License NPF-66 License NPF-66 Page 3 Page 3 TSs TSs 3.1.4-4 3.1.4-4 3.1.5-1 3.1.5-1 3.1.5-2 3.1.5-2 3.1.6-1 3.1.6-1 3.1.6-2 3.1.6-2 3.1.6-3 3.1.6-3 3.1.7-1 3.1.7-1 3.1.7-2 3.1.7-2 3.1.7-3 3.1.7-4

(2) Pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report, as supplemented and amended; (3) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

( 1) Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of 3645 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 202 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Deleted.

(4) Deleted.

Renewed License No. NPF-37 Amendment No. 202

(2) Pursuant to the Act and 1O CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Updated Final Safety Analysis Report, as supplemented and amended; (3) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. The renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

( 1) Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of 3645 megawatts thermal ( 100 percent rated power) in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendix A (NUREG-1113), as revised through Amendment No. 202 and the Environmental Protection Plan contained in Appendix B, both of which were attached to Renewed License No. NPF-37, dated November 19, 2015, are hereby incorporated into this renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Renewed License No. NPF-66 Amendment No. 202

Rod Group Alignment Limits 3.1.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.l Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition B or Required Action C.3 not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 -------------------NOTE--------------------

Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.

Verify position of individual rods within In accordance alignment limit. with the Surveillance Frequency Control Program SR 3.1.4.2 Verify rod freedom of movement In accordance (trippability) by moving each rod not fully with the inserted in the core~ 10 steps in either Surveillance direction. Frequency Control Program SR 3.1.4.3 Verify rod drop time of each rod, from the Prior to fully withdrawn position, is~ 2.7 seconds criticality from the beginning of decay of stationary after each gripper coil voltage to dashpot entry, removal of the with: reactor head

a. Tavg ~ 550°F; and
b. All reactor coolant pumps operating.

BYRON - UNITS 1 &2 3.1.4-4 Amendment 202

Shutdown Bank Insertion Limits 3.1.5 3.1 REACTIVITY CONTROL SYSTEMS 3.1.5 Shutdown Bank Insertion Limits LCO 3.1. 5 Each shutdown bank shall be within the insertion limits specified in the COLR.

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

Not applicable to shutdown banks inserted while performing SR 3.1.4.2.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One shutdown bank A.l Verify all control 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inserted~ 16 steps banks are within the beyond the insertion insertion limits limits specified in specified in the the COLR. COLR.

AND A. 2.1 Verify SOM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the limits specified in the COLR.

A. 2. 2 Initiate borati on to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SOM to within limit.

AND A.3 Restore the shutdown 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> bank to within the insertion limits specified in the COLR.

(continued)

BYRON - UNITS 1 &2 3.1.5-1 Amendment 202

Shutdown Bank Insertion Limits 3.1.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more shutdown B.1.1 Verify SOM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> banks not within the limits specified limits for reasons in the COLR.

other than Condition A. OR B.1.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SOM to within limit.

AND B.2 Restore shutdown 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> bank(s) to within limits.

C. Required Action and C.l Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify each shutdown bank is within the In accordance insertion limits specified in the COLR. with the Surveillance Frequency Control Program BYRON - UNITS 1 &2 3.1.5-2 Amendment 202

Control Bank Insertion Limits 3.1.6 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 Control Bank Insertion Limits LCD 3.1.6 Each control bank shall be within the insertion, sequence, and overlap limits specified in the COLR.

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

Not applicable to control banks inserted while performing SR 3.1.4.2.

APPLICABILITY: MODE 1, MODE 2 with keff ~ 1.0.

ACTIONS CONDITION REQU I RED ACTION COMPLETI,ON TIME A. Control bank A, B or C A.l Verify all shutdown 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inserted~ 16 steps banks are within the beyond the insertion, insertion limits sequence, or overlap specified in the limits specified in COLR.

the COLR.

AND A.2.1 Verify SOM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the limits specified in the COLR.

A. 2. 2 Initiate borati on to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SOM to within limit.

AND A.3 Restore the control 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> bank to within the insertion, sequence, and overlap limits specified in the COLR.

(continued)

BYRON - UNITS 1 &2 3.1.6-1 Amendment 202

Control Bank Insertion Limits 3.1.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Control bank insertion B.1.1 Verify SOM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> limits not met for the limits specified reasons other than in the COLR.

Condition A.

OR B.1.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SOM to within limit.

AND B.2 Restore control 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> bank(s) to within limits.

C. Control bank sequence C.1.1 Verify SOM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or overlap limits not the limits specified met for reasons other in the COLR.

than Condition A.

OR

.C.1.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SOM to within limit.

AND C.2 Restore control bank 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> sequence and overlap to within limits.

D. Required Action and D.l Be in MODE 2 with 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion keff < 1.0.

Time not met.

BYRON - UNITS 1 &2 3.1.6-2 Amendment 202

Control Bank Insertion Limits 3.1.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 Verify estimated critical control bank Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> position is within the limits specified in prior to the COLR. criticality SR 3.1.6.2 Verify each control bank is within the In accordance insertion limits specified in the COLR. with the Surveillance Frequency Control Program SR 3.1.6.3 Verify each control bank not fully In accordance withdrawn from the core is within the with the sequence and overlap limits specified in Surveillance the COLR. Frequency Control Program BYRON - UNITS 1 &2 3.1.6-3 Amendment 202

Rod Position Indication 3.1. 7 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Rod Position Indication LCD 3.1.7 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

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

Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.

CONDITION REQUIRED ACTION COMPLETION TIME A. One DRPI per group A.l Verify the position Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable in one or of the rods with more groups. inoperable DRPis.

OR A.2 Verify the position 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the rods with inoperable DRPis. AND Once per 31 EFPD thereafter AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after discovery of each unintended rod movement (continued)

BYRON - UNITS 1 &2 3.1.7-1 Amendment 202

Rod Position Indication 3.1. 7 CONDITION REQU I RED ACTION COMPLETION TIME A. (continued) 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after each movement of rod with inoperable DRPI

> 12 steps AND Prior to THERMAL POWER exceeding 50% RTP AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after reaching RTP OR A.3 Reduce THERMAL POWER 8 Hours to ~ 50% RTP.

B. More than one DRPI per B.1 Place the control Immediately group inoperable in rods under manual one or more groups. control.

AND B.2 Restore inoperable 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DRPis to OPERABLE status such that a maximum of one DRPI per grou~ is inoperab e (continued)

BYRON - UNITS 1 &2 3.1.7-2 Amendment 202

Rod Position Indication 3.1. 7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more DRPis C.l Initiate action to Inmediately inoperable in one or verify the position more groups and of the rods with associated rod has inoperable DRPis.

been moved> 24 steps in one direction since OR the last determination of the rod's position. C.2 Reduce THERMAL POWER 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to s 50% RTP.

D. One or more demand 0.1.1 Verify by Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> position indicators administrative means per bank inoperable all DRPis for the in one or more banks. affected bank(s) are OPERABLE.

AND 0.1.2 Verify the most Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> withdrawn rod and the least withdrawn rod of the affected bank(s) are s 12 steps apart.

OR 0.2 Reduce THERMAL POWER 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to s 50% RTP*.

E. Required Action and E. l Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

BYRON - UNITS 1 &2 3.1.7-3 Amendment 202

Rod Position Indication 3.1. 7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1. 7.1 ------------------NOTE--------------------- Prior to Not required to be met for DRPis associated criticality with rods that do not meet LCD 3.1.4. after each removal of the reactor head Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel.

BYRON - UNITS 1 &2 3.1.7-4 Amendment 202

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 196 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-72, AMENDMENT NO. 196 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-77, AMENDMENT NO. 202 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-37, AND AMENDMENT NO. 202 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-66 EXELON GENERATION COMPANY, LLC BRAIDWOOD STATION, UNITS 1 AND 2 BYRON STATION, UNIT NOS. 1 AND 2 DOCKET NOS. STN 50-456, STN 50-457, STN 50-454, AND STN 50-455

1.0 INTRODUCTION

By letter dated June 30, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17187A191), as supplemented by letters dated October 25, 2017 (ADAMS Accession No. ML172989536) and May 29, 2018 (ADAMS Accession No.

ML18149A637), Exelon Generation Company, LLC, (EGC, the licensee) submitted a license amendment request (LAR) to revise the technical specifications (TS) for Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2, to the U.S. Nuclear Regulatory Commission (NRC, the Commission). The supplements dated October 25, 2017 and May 29, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on August 29, 2017 (82 FR 41069).

Specifically, the application requests changes consistent with NRC-approved Technical Specifications Task Force {TSTF) Change Traveler TSTF-547, Revision 1, "Clarification of Rod Position Requirements." By letter dated December 31, 2015 (ADAMS Accession No.

ML15365A610), the TSTF submitted to the NRC Revision 1 to Change Traveler TSTF-547.

Change Traveler TSTF-547 proposes changes to Volumes 1 and 2 of NUREG-1431, Revision 4, "Standard Technical Specifications: Westinghouse Plants," dated April 2012 (ADAMS Accession Nos. ML12100A222 and ML12100A228, respectively). The proposed changes would revise the TS to provide time to repair rod movement failures that do not affect Enclosure 5

rod operability, correct conflicts between the TS, and increase consistency between the subject TS and improve the format and presentation.

1.1 Description of Rod Cluster Control Assemblies The rod cluster control assemblies (RCCA), or rods, are moved by their control rod drive mechanisms (CRDM). Each CRDM moves its RCCA one step (approximately 5/8 inch) at a time, but at varying rates (steps per minute) depending on the signal output from the rod control system. The RCCAs are divided among control banks and shutdown banks. Each bank may be further subdivided into two groups to provide for precise reactivity control. A group consists of two or more RCCAs that step simultaneously. If a bank of RCCAs consists of two groups, the groups are moved in a staggered fashion, but always within one step of each other. All units have four control banks and five shutdown banks.

The shutdown banks are maintained either in the fully inserted or fully withdrawn position. The control banks are moved in an overlap pattern using the following withdrawal sequence: when control bank A reaches a predetermined height in the core, control bank B begins to move out with control bank A. Control bank A stops at the position of maximum withdrawal, and control bank B continues to move out. When control bank B reaches a predetermined height, control bank C begins to move out with control bank B. This sequence continues until control banks A, B, and C are at the fully withdrawn position, and control bank D is approximately halfway withdrawn. The insertion sequence is the opposite of the withdrawal sequence. The control rods are arranged in a radially symmetric pattern, so that control bank motion does not introduce radial asymmetries in the core power distributions.

The control banks are used for precise reactivity control of the reactor. The positions of the control banks are normally automatically controlled by the rod control system, but they can also be manually controlled. They are capable of adding negative reactivity very quickly (compared to adding soluble boron). The control banks must be maintained above designed insertion limits and three of the four are typically near the fully withdrawn position during normal full power operations.

The axial position of shutdown rods and control rods is indicated by two separate and independent systems, which are the demand position indication system (commonly called group step counters) and the digital rod position indication (DRPI) system. The demand position indication system counts the pulses from the rod control system that moves the rods. There is one step counter for each group of rods. Individual rods in a group all receive the same signal to move and should, therefore, all be at the same position indicated by the group step counter for that group. The demand position indication system is considered highly precise (+/-1 step or

+/-5/8 inch); however, it is not a reliable indicator of rod position because it is a demanded position indication, not an actual position indication. If a rod does not move one step for each demand pulse, the step counter will still count the pulse but incorrectly reflect the position of the rod.

The DRPI system provides a more reliable indication of actual rod position, but at a lower precision than the step counters. This system is based on inductive analog signals from a series of coils spaced along a hollow tube with a center to center distance of 3. 75 inches or 6 steps. To increase the reliability of the system, the inductive coils are connected alternately to data channel A or B. Thus, if one data system fails, the DRPI will indicate rod position with an effective coil spacing of 7.5 inches or 12 steps. The DRPI system is capable of monitoring rod position within at least +/-12 steps.

2.0 REGULATORY EVALUATION

The categories of items required to be in the TSs are provided in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c). As required by 10 CFR 50.36(c)(2)(i), the TSs will include limiting conditions for operations (LCOs), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met. The regulation at 10 CFR 50.36(c)(3) requires TSs to include items in the category of surveillance requirements (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 LCOs will be met. Also, 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TSs.

The NRC staff's guidance for the review of TSs is in Chapter 16, "Technical Specifications," of NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition" (March 2010) (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared Standard Technical Specifications (STSs) for each of the LWR nuclear designs. NUREG-1431, Revision 4, contains the STSs for Westinghouse-designed plants.

3.0 TECHNICAL EVALUATION

3.1 Description of Proposed Changes This safety evaluation (SE) addresses proposed changes to TS 3.1.4, "Rod Group Alignment Limits," TS 3.1.5, "Shutdown Bank Insertion Limits," TS 3.1.6, "Control Bank Insertion Limits,"

and TS 3.1.7, "Rod Position Indication." The specific proposed changes are described in the following subsections. The discussion is applicable to both Braidwood and Byron Stations.

3.1.1 Provide Time to Correct Rod Movement Failures that Do Not Affect Operability The current TS 3.1.5 states in part:

LCO 3.1.5 Each shutdown bank shall be within the insertion limits specified in the COLR.

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

This LCO is not applicable while performing SR 3.1.4.2.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1.1 Verify SOM is 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> shutdown banks not within the limits within limits. specified in the COLR.

OR

A.1.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SDM to within limit.

AND A.2 Restore shutdown 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> bank(s) to within limits.

8. Required Action and 8.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met The proposed change would change the note to specifically refer to shutdown banks.

The proposed change would add a new Condition A to TS 3.1.5 that would require actions with one shutdown bank inserted s 16 steps beyond the insertion limits specified in the core operating limit report (COLR).

The existing Condition A would be renumbered as Condition 8 and would be modified to apply for one or more shutdown banks not within limits for reasons other than Condition A. The existing Required Actions (RAs) A.1.1, A.1.2, and A.2, would be renumbered as 8.1.1, 8.1.2, and 8.2. The existing Condition 8 and RA 8.1 would be renumbered as Condition C and RAC.1.

The shutdown banks must be within their insertion limits any time the reactor is critical or approaching criticality. This ensures that a sufficient amount of negative reactivity is available to shut down the reactor and maintain the required shutdown margin (SDM) following a reactor trip.

Therefore proposed TS 3.1.5 would state:

LCO 3.1.5 Each shutdown bank shall be within the insertion limits specified in the COLR.

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

Not applicable to shutdown banks inserted while performing SR 3.1.4.2.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One shutdown bank A.1 Verify all control 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inserted s 16 steps banks are within the beyond the insertion insertion limits limits specified in the specified in the COLR. COLR.

AND

A.2.1 Verify SDM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the limits specified in the COLR.

OR A.2.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SDM to within limit.

AND A.3 Restore the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> shutdown bank to within the insertion limits specified in the COLR.

B. One or more B.1.1 Verify SDM is 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> shutdown banks not within the limits within limits for specified in the reasons other than COLR.

Condition A.

OR B.1.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SDM to within limit.

AND B.2 Restore shutdown 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> bank( s) to within limits.

C. Required Action and C. 1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

The current TS 3.1.6 states, in part:

LCO 3.1.6 Each control bank shall be within the insertion, sequence, and overlap limits specified in the COLR.

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

This LCO is not applicable while performing SR 3.1.4.2.

APPLICABILITY: MODE 1, MODE 2 with l<eff 2::: 1.0.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Control bank insertion A.1.1 Verify SOM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> limits not met. the limits specified in the COLR.

OR A.1.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SOM to within limit.

AND A.2 Restore control 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> bank(s) to within limits.

B. Control bank B.1.1 Verify SOM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> sequence or overlap the limits specified limits not met. in the COLR.

OR B.1.2 Initiate boration to restore SOM to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> within limit.

AND B.2 Restore control bank sequence and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> overlap to within limits.

C. Required Action and C.1 Be in MODE 2 with 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated l<eff < 1.0.

Completion Time not met.

The proposed change would change the note to specifically refer to control banks.

The proposed change would add a new Condition A to TS 3.1.6 that would require actions, if control bank A, B, or C is inserted s 16 steps beyond the insertion, sequence, and overlap limits specified in the COLR.

The existing Condition A would be renumbered as Condition B and would be modified to apply for control bank insertion limits that are not met for reasons other than Condition A. The existing RAs A.1.1, A.1.2, and A.2, would be renumbered as 8.1.1, B.1.2, and B.2.

The existing Condition B would be renumbered as Condition C and would be modified to apply when control bank sequence or overlap limits are not met for reasons other than Condition A.

The existing RAs B.1.1, B.1.2, and 8.2 would be renumbered as C.1.1, C.1.2, and C.2. Existing Condition C and RA C.1 would be renumbered as Condition D and RA D.1.

The limits on control banks sequence, overlap, and physical insertion, as defined in the COLR, must be maintained because they serve the function of preserving power distribution, ensuring that the SDM is maintained, ensuring that ejected rod worth is maintained, and ensuring adequate negative reactivity insertion is available on trip.

Therefore, proposed TS 3.1.6 would state:

LCO 3.1.6 Each control bank shall be within the insertion, sequence, and overlap limits specified in the COLR.

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

Not applicable to control banks inserted while performing SR 3.1.4.2.

APPLICABILITY: MODE 1, MODE 2 with Keff::::: 1.0.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Control bank A, B or A.1 Verify all shutdown 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> C inserted s 16 steps banks are within the beyond the insertion, insertion limits sequence,oroverlap specified in the limits specified in the COLR.

COLR.

AND A.2.1 Verify SDM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the limits specified in the COLR.

OR A.2.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SDM to within limit.

AND A.3 Restore the control 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> bank to within the insertion, sequence, and overlap limits specified in the COLR.

B. Control bank insertion B.1.1 Verify SDM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> limits not met for the limits specified reasons other than in the COLR.

Condition A.

OR

B.1.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SOM to within limit.

AND 8.2 Restore control 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> bank( s) to within limits.

C. Control bank C.1.1 Verify SOM is within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> sequence or overlap the limits specified limits not met for in the COLR.

reasons other than Condition A. OR C.1.2 Initiate boration to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore SOM to within limit.

AND C.2 Restore control 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> bank sequence and overlap to within limits.

D. Required Action and D.1 Be in MODE 2 with 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated keff < 1.0.

Completion Time not met.

3.1.2 Provide an Alternative to Frequent Verification of Rod Position The current TS 3.1. 7 states, in part:

LCO 3.1.7 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

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

Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.

CONDITION REQUIRED ACTION COMPLETION TIME A. One DRPI per group A.1 Verify the position Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable for one or of the rods with more groups. inoperable DRPls.

OR A.2 Reduce THERMAL 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> POWER to s 50%

RTP.

B. One or more rods with B.1 Initiate action to Immediately inoperable DRPls verify the position of have been moved in the rods with excess of 24 steps in inoperable DRPls.

one direction since the last determination OR of the rod's position.

8.2 Reduce THERMAL 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> POWER to s 50%

RTP.

C. One demand position C.1.1 Verify by Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> indicator per bank administrative inoperable for one or means all DRPls for more banks the affected bank(s) are OPERABLE.

AND C.1.2 Verify the most Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> withdrawn rod and the least withdrawn rod of the affected bank(s) ares 12 steps apart.

OR C.2 Reduce THERMAL 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> POWER to s 50%

RTP.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

The TS 3.1.7, "Rod Position Indication," requires that the DRPI system and the demand positon indication system be operable during Startup and Power Operation. Condition A applies for one DRPI per group of rods inoperable for one or more groups of rods.

As noted in the TS Bases 3.1. 7, verification of rod position can be determined by use of either the moveable incore detectors or the Power Distribution Monitoring system (PDMS).

The proposed change would add a new RA to Condition A as an alternative to the once per 8-hour verification of rod position. Also, an editorial change would be made to Condition A and Condition C to change "for to "in." This would not change the technical meaning of the Conditions.

A new Condition B would be added. As noted above, the Braidwood and Byron TS were based on NUREG-1431, Revision 1, which did not have a condition for more than one DRPI per group inoperable. The new Condition B and RAs would be incorporated into the Braidwood and Byron TS. As a result of this addition, the existing Condition B would be renumbered as Condition C, the existing Condition C would be renumbered as Condition D, and the existing Condition D would be renumbered as Condition E.

The existing Condition B (renumbered as Condition C) would be revised to contain similar terminology to Condition A and the new Condition B for consistency.

The existing Condition C (renumbered as Condition D), would be revised from "One demand position indicator per bank inoperable for one or more banks" to "One or more demand position indicators per bank inoperable in one or more banks." The proposed change would make the terminology consistent with the Note that states, "Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator."

The 12-step agreement limit between the bank demand position indication system and the DRPI system indicates that the demand position indication system is adequately calibrated, and can be used for indication of the measurement of control rod bank position. When one DRPI per group fails, the position of the rod may still be determined indirectly by use of either the movable incore detectors or PDMS.

Therefore, proposed TS 3.1. 7 would state:

LCO 3.1. 7 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

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

Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.

CONDITION REQUIRED ACTION COMPLETION TIME A. One DRPI per group A.1 Verify the position Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable in one or of the rods with more groups. inoperable DRPls.

OR A.2 Verify the position 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the rods with inoperable DRPls AND Once per 31 EFPD thereafter AND

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after discovery of each unintended rod movement AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after each movement of rod with inoperable DRPI

> 12 steps AND Prior to THERMAL POWER exceeding 50% RTP AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after reaching RTP OR A.3 Reduce THERMAL 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> POWER to !:> 50%

RTP.

B. More than one DRPI B.1 Place the control Immediately per group inoperable rods under manual in one or more groups control.

AND B.2 Restore inoperable 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DRPls to OPERABLE status such that a maximum of one DRPI per group is inoperable.

C. One or more DRPls C. 1 Initiate action to Immediately inoperable in one or verify the position of more groups and the rods with associated rod has inoperable DRPls.

been moved> 24 steps in one direction OR since the last C.2 Reduce THERMAL 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

determination of the POWER to s 50%

rod's position. RTP.

D. One or more demand D.1.1 Verify by Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> position indicators per administrative bank inoperable in means all DRPls for one or more banks. the affected bank( s) are OPERABLE.

AND D.1.2 Verify the most Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> withdrawn rod and the least withdrawn rod of the affected bank(s) ares 12 steps apart.

OR D.2 Reduce THERMAL 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> POWER to s 50%

RTP.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

3.1.3 Correct Conflicts Between TS 3.1.4 and TS 3.1. 7 The current SR 3.1.4.1 states:

SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify individual rod positions within alignment limit. In accordance with the Surveillance Frequency Control Program The SR 3.1.4.1 requires verification that individual rod positions are within the alignment limits in accordance with the surveillance frequency control program (SFCP). The proposed change is the addition of a Note to SR 3.1.4.1 stating that the SR is not required to be performed for rods associated with inoperable rod position indicator or demand position indicator. This Note is proposed to be added because SR 3. 1.4. 1 cannot be performed for rods with an inoperable demand position indicator. An editorial wording change is also proposed for SR 3.1.4.1 to make it consistent with the wording of TS 3.1. 7 RA A.1.

Therefore, proposed SR 3.1.4.1 would state:

SURVEILLANCE FREQUENCY SR 3.1.4.1 - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - In accordance Not required to be performed for rods associated with the with inoperable rod position indicator or demand Surveillance position indicator. Frequency

Control Program Verify position of individual rods within alignment limit.

The current SR 3.1. 7.1, states:

SURVEILLANCE FREQUENCY SR 3.1.7.1 Verify each DRPI agrees within 12 steps of the group Prior to criticality after demand position for the full indicated range of rod each removal of the travel. reactor head The LCO 3.1.4 specifies that all shutdown and control rods shall be operable and individual indicated rod positions shall be within 12 steps of their group step counter demand position.

SR 3.1. 7.1 requires verification that each DRPI agrees within the required steps of the group demand position for the full indicated range of rod travel. The proposed change is the addition of a Note to SR 3.1. 7 .1 stating that the SR would not be required to be met for rods that do not meet LCO 3.1.4.

Therefore, proposed SR 3.1.7.1 would state:

SURVEILLANCE FREQUENCY SR 3.1.7.1 - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - Prior to criticality after Not required to be met for DRPls associated with each removal of the rods that do not meet LCO 3.1.4. reactor head

Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel.

3.1.4 Other Proposed Changes The proposed changes described in this section are editorial and do not change the technical content.

1. TSTF-547 proposes to eliminate TS 3.1.4, Condition 8, RA 8.1, and to combine RAs 8.2.4 and 8.2.5. RA 8.1 was previously eliminated during the Braidwood and Byron Station TS transition from current technical specifications {CTS} to NUREG-1431, Revision 1. RAs 8.2.4 and 8.2.5 were previously combined in Amendment 110 (Braidwood Station) and Amendment 116 (Byron Station) (ADAMS Accession No.

ML010510325). No additional changes are necessary.

2. LCO 3.1.5 and LCO 3.1.6 contain a Note modifying their Applicability that states "This LCO is not applicable while performing SR 3.1.4.2." The proposed change would revise the Notes to state: "Not applicable to shutdown banks inserted while performing SR 3.1.4.2," for LCO 3.1.5; and "Not applicable to control banks inserted while

performing SR 3.1.4.2," for LCO 3.1.6. This change clarifies the Note and does not alter its meaning.

3. In TSTF-547, TS 3.1.7 is revised to consistently use the defined abbreviation "DRPI."

This affects the Actions Note, RA A.1, RA B.2, and RA C.1. Consistent use of the defined abbreviation "DRPI" was previously adopted during the Braidwood and Byron Station TS transition from CTS to NUREG-1431, Revision 1; therefore, this change is not applicable to the Braidwood and Byron Station TS.

4. TS 3.1. 7, Condition A, is revised from "for one or more groups" to the more standard terminology "in one or more groups." This change does not alter the meaning.
5. TSTF-547 proposes to delete TS 3.1. 7, RA B.3, as it is redundant to RA A.1. As noted above, the Braidwood and Byron Station TS were based on NUREG-1431 Revision 1, which did not have a condition for more than one DRPI per group inoperable (i.e., no TS 3.1.7, Condition B). The new Condition Band associated RAs (as shown in TSTF-547) will be incorporated into the Braidwood and Byron Station TS; therefore, deletion of RA B.3 is not applicable.
6. The existing TS 3.1.7, Condition B (renumbered as Condition C), is revised to contain similar terminology to Condition A and the new Condition B for consistency. The current wording of the existing Condition B states, "One or more rods with inoperable DRPls have been moved in excess of 24 steps in one direction since the last determination of the rod's position." The proposed change rewords the renumbered Condition C to state:

"One or more DRPls inoperable in one or more groups and associated rod has been moved >24 steps in one direction since the last position determination." This change does not alter the meaning.

7. The existing TS 3.1.7, Condition C (renumbered as Condition D), is revised from "One demand position indicator per bank inoperable for one or more banks" to "One or more demand position indicators per bank inoperable in one or more banks." The proposed change makes the terminology consistent with the Note modifying the RAs as discussed in the following paragraph.

The current TS 3.1. 7 is modified by a Note which states, "Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator." The Bases for the Note state that the Note is acceptable because the RAs for each Condition provide appropriate compensatory actions for each inoperable indicator. There is one demand position indicator per group of rods. For banks with two groups of rods, there are two demand indicators per bank. The separate condition entry Note modifying the TS 3.1. 7 Actions states that separate condition entry is allowed for each inoperable demand position indicator which means that the renumbered Condition D is applicable to more than one inoperable demand position indicator per bank. The proposed change makes the renumbered Condition D terminology consistent with the Note.

3.2 Evaluation The NRC staff reviewed the proposed changes to the TSs and the technical justification for the changes proposed in the license amendment request (LAR) to ensure that the reasoning was logical, complete, and clearly written as described in Chapter 16 of NUREG-0800. The NRC staff also reviewed the proposed changes for continued compliance with the requirements of 1O CFR 50.36 and for consistency with conventional terminology and with the format and usage

rules embodied in the STS. In its SE for TSTF-547, Revision 1, the NRC staff did not specify any limitations or conditions for adoption of the Traveler by future applicants.

Although the TS bases are not part of the TS, the NRC staff confirmed that the TS bases described the basis for each revised TS requirement accurately as described in Chapter 16 of NUREG-0800.

3.2.1 Provide Time to Correct Rod Movement Failures that Do Not Affect Operability The proposed new Condition A of TSs 3.1.5 and 3.1.6 for shutdown and control bank insertion limits would allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore a single bank to be within its insertion limit when inserted below the insertion limit. With one shutdown or control bank inserted a maximum of 16 steps below the rod insertion limit, the RAs associated with new Condition A would also require verification that all other control and shutdown banks are within the insertion limits; and verification that the SOM is maintained or established. The completion time (CT) for these RAs would be 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

The new conditions define limits of both duration and insertion if a bank is immovable due to failures external to the CROM. A maximum of one control or shutdown bank may be inserted beyond the limits for a maximum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided all other banks are within the insertion limits and that the reactor could be shut down using control rods or boration. The new Condition A imposes a limit of s 16 steps beyond the insertion limit. Given that SR 3.1.4.2 requires movement of the control and shutdown rods a minimum of 10 steps in either direction, the NRC staff asked the licensee to provide justification for the use of s 16 steps in Condition A in LCOs 3.1.5 and 3.1.6 and explain how this is consistent with that approved in the NRC staff's SE for TSTF-547. In its letter dated October 25, 2017, the licensee responded as follows:

The selection "s 16 steps" for these LCOs is consistent with the statement in the NRC's Safety Evaluation for TSTF-547 that specifies: "The value of [16] steps corresponds to the minimum number of steps that the rods must be moved to ensure correct performance of SR 3.1.4.2." The value of 16 steps is based on the design of the Digital Rod Position Indication (DRPI) System.

The licensee then went on to describe the DRPI system design. Based on the design, a light emitting diode (LED) will illuminate every 6 steps of rod movement. Therefore, to verify 10 steps of rod movement, a change of two LEDs must be observed, i.e., the bank must be inserted 12 steps, as an insertion of only 10 steps may result in only one DRPI LED change. In addition, normal DRPI system accuracy is +/-4 steps. Therefore, the value of 16 steps corresponds to the minimum number of steps that the rods must be moved to ensure correct performance of SR 3.1.4.2. Based on the licensee's explanation, the NRC staff finds that the plant-specific value of s 16 steps is appropriate to meet the requirements of SR 3.1.4.2 and is acceptable for use in LCOs 3.1.5 and 3.1.6.

The NRC staff reviewed the justification for the proposed addition of Condition A to TS 3.1.5 and TS 3.1.6 provided in the Technical Evaluation Section of Traveler TSTF-547, to ensure that the reasoning is logical, complete, and clearly written. The justification in Traveler TSTF-547 states:

1. All control and shutdown rod assemblies are required to be Operable. If a rod is untrippable (i.e., inoperable), then a plant shutdown is required in accordance with LCO 3.1.4, Condition A.
2. Only one control bank and shutdown bank may be inserted beyond insertion limits by no more than 16 steps. If one or more control banks or shutdown banks

exceed the insertion limit, a brief time period is permitted to correct the condition and then a plant shutdown is required.

3. If one rod is not within the alignment limits, adequate SDM is verified and a power reduction is required by LCO 3.1.4, Condition B. If more than one rod is not within the alignment limit as defined in LCO 3.1.4, adequate SDM is verified and a plant shutdown is required.

The insertion limits are established to ensure a sufficient amount of negative reactivity can be rapidly inserted to shut down the reactor. The NRC staff finds that allowing continued full-power operations for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with a rod movement failure is acceptable for the following reasons:

1. shutdown margin continues to be met;
2. all control and shutdown rods are trippable - i.e., capable of being rapidly inserted into the core;
3. only one bank may exceed insertion limits by no more than a specified number of steps;
4. all immovable rod assemblies are aligned; and
5. the rods must be restored to within the insertion limits within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The change to TSs 3.1.5 and 3.1.6 to provide time to correct rod movement failures that do not affect operability will allow sufficient time for diagnosis and repairs while maintaining the safety function of the control rods since the affected rods are still trippable. The thermal margins may be affected by power distribution changes due to control rod bank insertion, both during the insertion and during the resulting local xenon transient. However, insertions at or near the typical value of 16 steps from fully withdrawn, as provided in the proposed changes to TSs 3.1.5 and 3.1.6, would result in a very small negative reactivity impact at the top of active fuel. The resulting effect on the axial power distribution is not expected to be significant. In addition, alignment of all rods with the rod bank position (as per LCO 3.1.4) must be maintained and it will be verified that the reactor can still be shut down. Therefore, the NRC staff has determined that the proposed 24-hour CT for Condition A in TSs 3.1.5 and 3.1.6 specifying shutdown bank and control bank insertion limits is acceptable.

The NRC staff concludes that TS 3.1.5 and TS 3.1.6, as modified by the addition of Condition A, continue to specify the minimum performance level of equipment needed for safe operation of the facility as an LCO; and continue to specify the appropriate remedial measures if the LCO is not met. SRs are not being changed by the addition of Condition A. The NRC staff finds that the requirements of 10 CFR 50.36(c)(2) continue to be met because the minimum performance level of equipment needed for safe operation of the facility is contained in the LCO and the appropriate remedial measures are specified if the LCO is not met.

3.2.2 Provide an Alternative to Frequent Verification of Rod Position The LCO 3.1. 7 requires that the DRPI and the demand position indication system be Operable during Power Operation and Startup. When one or more DRPI per group are inoperable for one or more groups, current TS 3.1. 7 requires verification of rod position once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> using the movable incore detectors or PDMS or to reduce thermal power to less than or equal to 50 percent rated thermal power (RTP) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The proposed change would provide an alternative set of RAs.

New RA A.2 would require the use of the movable incore detector system or PDMS to verify the position of the rod within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the inoperability of DRPI, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after discovery of each unintended rod movement, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after each greater than 12 step movement of a rod with inoperable DRPI, prior to exceeding 50 percent RTP, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after reaching RTP, and once per 31 effective full power days thereafter.

TSTF-547 proposed a new RA A.2.2 that would require the inoperable DRPI to be restored to operable status prior to entering startup (MODE 2) from hot standby (MODE 3). In its letter dated May 29, 2018, the licensee requested to not include this RA. The licensee provided justification that showed that this RA would never be limiting or implemented because the RAs are joined by a logical "OR," any one of the RAs may be chosen. In addition, when an LCO is not met, LCO 3.0.4.a allows entry into a MODE in which an LCO is applicable when the associated actions to be entered permit continued operation in the MODE for an unlimited period of time. Since the LCO permits continued operation with the specified RAs, entering startup from hot standby is allowed. Based on the above, the NRC staff determined that not including a new RA A.2.2 is appropriate because it is unnecessary and could cause confusion.

The implementation of new RA A.2 would allow the use of an alternative monitoring scheme.

This alternative method reduces potential wear on the movable incore detector system when PDMS is inoperable and also reduces the time required to perform the frequent rod position verifications. The NRC staff finds that the new RA A.2 and CT is appropriate because it requires verification of rod position following circumstances in which rod motion could occur.

This is a more tailored approach than current TS 3.1. 7 RA A.1, which requires verification of rod position using the moveable incore detector system or PDMS once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, regardless of whether the rods have moved.

If the rod position indication is failed for an individual rod, its position is determined indirectly by the use of the moveable incore detectors or PDMS. The NRC staff has determined that this change, which verifies rod position based on the occurrence of events requiring rod motion, rather than determining position on a specified frequency, is acceptable because events requiring rod motion of the shutdown banks and control banks A, B, and C are relatively infrequent during steady state operation. Events involving significant movement of rods in control bank D are also relatively infrequent. The indirect determination of rod position is required after significant changes in power level or following substantial rod motion.

The addition of the Note to SR 3.1.4.1 stating that the SR is not required to be performed for rods associated with an inoperable rod position indicator or demand position indicator is appropriate because the RAs of TS 3.1. 7 for an inoperable DRPI provide the appropriate actions for indirectly determining the position of the affected rods.

The NRC staff concludes that the addition of an alternative monitoring scheme to indirectly determine the position of rods associated with an inoperable DRPI is acceptable. TS 3.1. 7, as modified, continues to specify the minimum performance level of equipment needed for safe operation of the facility as an LCO and continues to specify the appropriate remedial measures if the LCO is not met. The revised SR 3.1.4.1, which has been clarified to specify when it is required to be performed, continues to be an appropriate test to ensure that the necessary quality of systems is maintained. The NRC staff finds that the requirements of 10 CFR 50.36(c)(2) continue to be met because the minimum performance level of equipment needed for safe operation of the facility is contained in the LCO and the appropriate remedial measures are specified if the LCO is not met. The NRC staff finds that the requirements of 10 CFR 50.36(c)(3) continue to be met because the revised SR provides the appropriate testing to ensure the necessary quality of components is maintained and that the LCO will be met.

3.2.3 Correct Conflicts Between TS 3.1.4 and TS 3.1. 7 The LCO 3.1.4 requires that all shutdown and control rods shall be operable and individual indicated rod positions shall be within 12 steps of their group step counter demand position.

SR 3.1.4.1 requires verification of the individual rod positions within the alignment limit periodically. SR 3.1.4.1 cannot be performed for rods with an inoperable bank demand position indicator. Failure to meet an SR is considered a failure to meet an LCO requirement.

Therefore, if SR 3.1.4.1 cannot be performed, entry into LCO 3.1.4 Condition C is required.

LCO 3.1.4, Condition C, applies when more than one rod is not within the alignment limit. The RA associated with Condition C requires, in part, that the reactor be in hot standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

LCO 3.1. 7 requires the DRPI system and the demand position indication system to be operable.

Current LCO 3.1. 7, Condition C, applies if one indicator per bank is inoperable for one or more banks. The Condition C RAs require verification that all DRPls for the affected banks are operable and require verification that the most withdrawn rod and least withdrawn rod of the affected banks are less than or equal to 12 steps apart once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Alternatively, thermal power must be reduced to less than or equal to 50 percent RTP.

A Note would be added to SR 3.1.4.1 stating that this SR is not required to be performed for rods associated with an inoperable rod position indicator or demand position indicator. The alignment limit is based on the demand position indicator. If the bank demand position indicator is inoperable, the SR cannot be performed.

Following the proposed modification of SR 3.1.4.1, Condition D (renumbered current Condition C) of LCO 3.1.7 would be the applicable condition to be entered in the event of inoperable demand position indicators. The RAs associated with Condition D of LCO 3.1. 7 provide the appropriate actions in this situation by requiring that the DRPls are operable and that the individual rods in the bank are not misaligned by more than 12 steps.

The SR 3.1. 7 .1 requires verification that each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel. This SR is performed once prior to criticality after each removal of the reactor head. Failure to meet an SR is considered a failure to meet the LCO per SR 3.0.1. The requirements of SRs must be satisfied in between performances of the surveillance test itself. Therefore, if a control or shutdown rod is not within 12 steps of its bank demand position indication, then the requirements of both LCO 3.1.4 and LCO 3.1. 7 are not met.

A Note would be added to SR 3.1. 7 .1 stating that this SR is not required to be met for DRPls associated with rods that do not to meet LCO 3.1.4. If a rod is known not to be within 12 steps of the group demand position, LCO 3.1.4 provides the appropriate RAs. With one rod not within the alignment limit, Condition B requires verification of shutdown margin or boration until SDM is met, reduction in RTP, verification of shutdown margin once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, verification of hot channel factors within limits, and reevaluation of safety analyses and confirming that continued operation is permissible. If more than one rod is misaligned, the SDM must be verified to be within limits or boration must be initiated to restore required SDM, and the plant must be shut down.

The NRC staff reviewed the technical justification for the proposed changes provided in the LAR and TSTF-547 for logical reasoning, completeness, and clarity. The purpose of the changes is to prescribe the appropriate Actions to be followed when equipment is inoperable.

The TS 3.1.4 provides limits on rod alignment to ensure acceptable power peaking factors and local linear heat rates and an acceptable shutdown margin, all of which are initial conditions in the applicable safety analyses. It is appropriate to consolidate requirements associated with rod misalignments in this TS. TS 3.1. 7 provides requirements for instrumentation to monitor rod position. The instrumentation is used to verify that the rod alignment limits in TS 3.1.4 are satisfied. Similarly, it is appropriate to consolidate requirements associated with instrumentation operability in this TS.

The NRC staff concludes that the clarification notes to SRs 3.1.4.1 and 3.1.7.1 to specify configurations in which performance of the SRs is not required are appropriate. The TSs, as modified, continue to specify the minimum performance level of equipment needed for safe operation of the facility as an LCO, and continue to specify the appropriate remedial measures if the LCO is not met. The revised SRs 3.1.4.1 and 3.1.7.1 continue to be appropriate, because they ensure the necessary quality of systems is maintained and that the LCOs will be met.

Based on the above, the NRC staff finds that the requirements of 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3) continue to be met.

3.2.4 Other Proposed Changes The changes described above in Section 3.1.4 were proposed to improve the presentation of the requirements or are administrative in nature.

The LCOs 3.1.5 and 3.1.6 contain a Note modifying their Applicability that states: "This LCO is not applicable while performing SR 3.1.4.2." The proposed change would revise the Notes to state: "Not applicable to shutdown banks inserted while performing SR 3.1.4.2," for LCO 3.1.5 and "Not applicable to control banks inserted while performing SR 3.1.4.2," for LCO 3.1.6. The NRC staff finds that this change is administrative in nature and does not alter the Note's meaning.

TS 3.1.7, Condition A, would be revised from "for one or more groups" to the more standard terminology "in one or more groups." The NRC staff finds that this change is administrative in nature and does not alter the condition's meaning.

The existing TS 3.1.7, Condition B (renumbered as Condition C), is revised to contain similar terminology to Condition A and the new Condition B for consistency. The current wording of the existing Condition B states, "One or more rods with inoperable DRPls have been moved in excess of 24 steps in one direction since the last determination of the rod's position." The proposed change rewords the renumbered Condition C to state, "One or more DRPls inoperable in one or more groups and associated rod has been moved > 24 steps in one direction since the last position determination." The NRC Staff finds that this change is administrative in nature and does not alter the condition's meaning.

The existing TS 3.1.7, Condition C (renumbered as Condition D), is revised from "One demand position indicator per bank inoperable for one or more banks" to "One or more demand position indicators per bank inoperable in one or more banks." The NRC staff finds that this change makes the.terminology consistent with the Note modifying the RAs and that this change is administrative in nature and does not alter the condition's meaning.

There were several items noted in the LAR which state that TSTF-547 changes are not being applied as they are not applicable. This is due to TSTF-547 being based on NUREG-1431, Revision 4, while Braidwood and Byron Station TS are based on Revision 1. As an example, TSTF-547 deletes TS 3.1.7, Required Action 8.2, "Monitor and record Reactor Coolant System

Tavg." The Braidwood and Byron Station TS do not have the subject Condition 8, so deletion of the associated RA B.2 is not applicable. Note that EGC did not request adopting TSTF-547 verbiage in its entirety due to variations from TSTF-547 that already exist in the current Braidwood Station and Byron Station TS. Therefore, the NRC staff reviewed only the proposed changes and did not review TSTF-547 modifications that were not proposed.

3.3 Summary of NRC Staff Conclusions The regulations at 10 CFR 50.36 require that TSs include items in specified categories, including LCOs and SRs. The proposed changes would modify the LCOs, Conditions, RAs, CTs, and SRs applicable to control rod and shutdown rod insertion and alignment limits and the instrumentation to monitor rod position and alignment. The TSs would continue to specify the LCOs and specify the remedial measures to be taken if one of these requirements is not satisfied. The TSs would continue to specify the appropriate SRs for tests and inspections to ensure the necessary quality of affected structures, systems, and components is maintained and that the LCOs will be met. Based on the above, the NRC staff concludes that the proposed LCOs and SRs meet the requirements of 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3),

respectively, and are, therefore, acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendments on March 1, 2018. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission previously issued a proposed finding on August 29, 2017 (82 FR 41069), that the amendments involve no significant hazards consideration, and there has been no public comment on such finding. The supplements dated October 25, 2017 and May 29, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination.

Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR Section 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the

amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: R. Beaton Date of issuance: June 2 7 , 2018

B. Hanson

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2, AND BYRON STATION, UNIT NOS.

1 AND 2 - ISSUANCE OF AMENDMENTS REGARDING CLARIFICATION OF ROD POSITION REQUIREMENTS (CAC NOS. MF9951, MF9952, MF9953, AND MF9954; EPID L-2017-LLA-0249) DATED JUNE 27, 2018 DISTRIBUTION:

PUBLIC RidsNrrDirsltsb Resource RidsRgn3MailCenter Resource RidsNrrDorllpl3 Resource RidsNrrLASRohrer Resource RidsNrrPMByron Resource RidsNrrDorlDpr Resource RidsNrrPMBraidwood Resource RidsACRS_MailCTR Resource Accession No. ML18065A529 *via memo **via e-mail OFFICE DORL/LPL3/PM DORL/LPL3/LA SRXB/BC(A) SNPB/BC NAME JWiebe SRohrer JWhitman* Rlukes*

DATE 6/4/18 3/7/18 2/8/18 2/8/18 OFFICE STSB/BC OGC** DORL/LPL3/BC DORL/LPL3/PM NAME VCusumano JLW NLO DWrona JWiebe DATE 6/6/18 6/12/18 6/27/18 6/27/18 OFFICIAL RECORD COPY

Retrieved from "https://kanterella.com/w/index.php?title=ML18065A529&oldid=1946075"