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| .~1400 Opus Place -
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| YO' '. Downers Grove, Illinois 60515 .
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| . March-21,1994
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| Mr. William Russell, Director Office of Nuclear Reactor Regulation
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| ~ U.S. Nuclear Regulatory Commission
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| ~ Washington, D.C. 20555 Attn: Document Control Desk
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| ==Subject:==
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| Byron Units 1 and 2 ,
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| v Braidwood Units 1 and 2 Request for EMERGENCY TECHNICAL SPECIFICATION AMENDMENT. i Facility Operation Licenses: NPF-37, NPF-66, NPF-72 and NPF R Technical Specification Section 3/4.7.1 NRC Docket Nos.~50-454. 50-455 50-456 and 50-457 i
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| ==Reference:==
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| D. Saccomando Letter to J. Zwolinski dated March 11,1994, !
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| transmitting Notice of. Enforcement Discretion Pertaining to- -!
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| Byron and Braidwood Station Main Steam Safety Valve !
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| ==Dear Mr. Russell:==
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| Pursuant to 10 CFR 50.91(a)(5), Commonwealth Edison _ Company'(CECO) proposes -
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| to amend Appendix A, Technical Specifications of Facility. Operating License ~s.-
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| NPF-37, NPF-66, NPF-72 and NPF-77, ~ and requests that the Nuclear Regulatory .
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| -. Commission (NRC)~ grant an.. EMERGENCY amendment to Technical Specification' ,
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| Section 3/4.7.1 " Turbine Cycle Safety Valves" Consistent with NRC guidance, a- .
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| request for an NRR Notice of Enforcement Discretion (NOED) for the ~ period until this q amendment can be granted was provided in the reference letter, ,
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| l Technical Specification 3.7.1.1 states that," Ali main steam line code safety valves -
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| associated with each steam generator shall be OPERABLE with lift settings as specified in Table 3.7-2." The proposed amendment will allow the' current as-left.
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| setpoints to be acceptable until they can be reset within the time frame described in
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| . the amendment.
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| - At the time of issuance of the Notice of Enforcement Discretion (NOED) Braidwood
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| : Unit 2 and Byron Units 1 and 2 were operating in Mode 1. The proposed' amendment- i
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| < would add a footnote to Table 3.7-2 which states / Main steam line code. safety valve
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| . lift settings'may have a ~+/-3% tolerance;until May 9,' 1994, by which time' the lift., ,
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| . settings will be reset to +/-1%."
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| 300057 9403310016 940321 4 kinla:brwd:mssvts:1- PDR ADOCK:05000454 p- . . ,
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| .W. Russell March 21,1994 in addition, at the time of issuance of the NOED, Braidwood Unit 1 was in a refuel outage. An amendment to Braidwood Technical Specification 4.7.1.1 will be necessary to facilitate resetting of the setpoints. The proposed amendment adds the statement: "The provisions of Specification 4.0.4 are not applicable for Braidwood Unit 1 Cycle -5 until the initial entry into Mode 2."
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| The attached safety analysis shows that this proposal will have minimal impact on l safety. Amending Section 3/4.7.1 to allow for the Main Steam Safety Valve setpoint to be greater than the allowed maximum of +/-1% would not impact the safety margin, .j because the Main Steam Safety Valves had been previously analyzed for as-found l setpoints of up +/ .3%. All valves for the four units fall within +/-3% of the nominal :
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| setpoint for the individual valve. I I
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| This emergency change could not be avoided because CECO only recently became informed of the need to reset the setpoints by the vendor.
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| The situation was not created by a failure to make a timely application of the Technical Specification Amendment because prior to notification from the vendor, CECO was I unaware that an improper value for mean seat areas was used in calculations the Main Steam Safety Valve setpoints.
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| In support of this request, the following information is attached: .!
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| Attachment A: Detailed Description Of The Proposed Changes Attachment B: ' Revised Technical Specification Pages . ,
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| . Attachment C: Evaluation of Significant Hazards Considerations 1 Attachment D: Environmental Assessment l l
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| Pursuant to 10CFR50.91(b)(1) a copy of this request has been forwarded to the designated State of Illinois Official.
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| To the best of my knowledge and belief, the statements contained in this document are true and correct. In some respects these statements are not based on my ,
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| personal knowledge, but on information furnished by other CECO employees, contractor employees, and/or consultants. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.
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| . . . ~ .-
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| I JW. Russell March 21,1994 -
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| Please address any comments or questions regarding this matter to this office.
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| Respectfully, 1
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| e j .4 ,
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| lnd ne ,~fo Denise W Saccomando Nuclear Licensing Administrator Attachments 1
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| cc: R. Assa, Braidwood Project Manager - NRR G. Dick, Byron Project Manager - NRR S. Dupont, Senior Resident inspector - Braidwood H. Peterson, Senior Resident inspector - Byron B. Clayton, Branch Chief - Region Ill Office of Nuclear Facility Safety - IDNS 1W LW h./ 3bs/9'/
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| v:::::::::::::::::::::::::::4 OFFICIAL SEAL l!
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| MARYELLEN D LONG !;
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| NOT ARY ftBLIC, ST ATE OF fLLINOISll MY COMMISSION EXPtRES:09/01/97 il v.v.v.v::f#####.vd k:nla:brwd:mssvtst3
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| .. . i ATTACHMENT A DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED' CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSES NPF-37, NPF-66, NPF-72, AND NPF-77 DESCRIPTION OF THE PROPOSED CHANGE Commonwealth Edison Company proposes a one time revision to Turbine Cycle Safety Valve Technical Specification 3.7.1.1 Surveillance Requirements and Technical .
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| Specification 3.7.1.1 Table 3.7-2.
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| The proposed Technical Specification Revisions include:
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| : 1. Adding a statement to the Surveillance Requirements stating that the provisions of Specification 4.0.4 are not applicable for Braidwood Unit 1 Cycle 5 until the initial entry into MODE 2,
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| : 2. Adding a provision to Table 3.7-2 allowing main steam line Code safety valve lift settings to have a 13% tolerance until May 9,1994, by which time the lift settings will be roset to 21%.
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| The revised Technical Specification pages indicating the proposed changes are provided in Attachment B. A discussion of the proposed changes follows.
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| Descdntion and Bases of the Current Rp_quigineJ11 ,
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| The Main Steam Safety Valves (MSSV) are currently required to be set within a lift setting tolerance of 1%. Technical Specification 3.7.1.1 Action Statement "a" states that with one or more MSSVs inoperable, operation in MODES 1,2, and 3 may proceed provided the valve is restored to OPERABLE status or the Power Range High Flux trip setpoints are reduced within 4 hours. lf these requirements are not met, the plant is required to be in HOT STANDBY in 6 hours and COLD SHUTDOWN in the
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| , next 30 hours.
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| The safety valves limits secondary pressure to within 110% of design pressure of 1200 psia during the most severe anticipated operating transient (Turbine Trip at 102%
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| Rated Thermal Power with no steam dumps available).
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| k:nla:brwd:mssvts:4
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| l l ' RenGEip.tipD_and3aSRS_of t!1e_Begunigd Revision At about 1730 hours on March 9,1994, Braidwood System Engineering received a phone call from Furmanite Company indicating that an improper value for mean seat area was used in the Trevitest calculation for main steam safety valve setpoints. i l Additional phone calls on March 10,1994, and a letter from Furmanite revealed that !
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| l the scope of the concern also included Byron Station. Calculations to determine the l as-left condition of the MSSVs for each unit based on the revised mean seat area 1 were completed at approximately 1500 hours on March 10,1994. Results indicate that 16 valves for Byron Unit 1,19 valves for Byron Unit 2, and 17 valves each for l Braidwood Units 1 and 2 fall outside of the Technical Specification requirement of i 1% All valves for the four Units fall within $3% of the nominal setpoint for the j individual valves.
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| The proposed emergency Technical Specification amendment will allow the current as- i left setpoints for Braidwood Unit 2, and Byron Units 1 and 2 to be acceptable until they l
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| can be reset. It allows Braidwood Unit 1, currently in refueling outage, to reach MODE ,
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| 3 to reset the valves. Based upon unit operating schedules and Furmanite availability, i l
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| the safety valves for Braidwood Unit 2, and Byron Units 1 and 2 will be reset on or l l before May 9,1994. The valves for Braidwood Unit 1 will be reset prior to reaching 1 l MODE 2 following the current refueling outage. I impaclof the_Changejs 1
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| l The requested changes to Specification 3.'7.1.1 due to the as-left setpoints of the !
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| l MSSVs being greater than the allowed maximum of 21% but within t 3% do not impact the safety margin. The MSSVs are analyzed for as-found setpoints of *3%,
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| which Commonwealth Edison Company will apply for in an upcoming amendment request.
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| The effects of increasing the as-found lift setpoint tolerance on the MSSV have been examined, and it has been determined that, with the exception of the Loss of
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| ; Load / Turbine Trip, the current accident analyses as presented in the UFSAR remain I
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| valid. The loss of load / turbine trip event was analyzed in order to quantify the impact l of the setpoint tolerance relaxation. All applicable acceptance criteria for this event l remain satisfied and the conclusion presented in the UFSAR remains valid.
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| The conclusions presented in the Overpressure Protection Report remain valid.
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| No operating conditions or modes will be changed as a result of this evaluation. No new failure modes have been determined to exist as a result of this new analysis. The MSSVs will continue to relieve any unlikely system overpressure during all applicable l operating modes. The increased as-found setpoint tolerance has no significant negative impact on any system, operating mode, or accident analysis.
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| SCHEDULE REQUIREMENTS l.
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| l This amendment is needed for the startup of Braidwood Unit 1. Therefore, CECO requests that this amendment be approved prior to April 17,1994.
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