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| FINAL RESPONSE TO TASK INTERFACE AGREEMENT 2012-13, BRAIDWOOD STATION TECHNICAL SPECIFICATION 3.6.3 COMPLIANCE WITH ONE OR MORE MAIN STEAM ISOLATION VALVES INOPERABLE | | FINAL RESPONSE TO TASK INTERFACE AGREEMENT 2012-13, BRAIDWOOD STATION TECHNICAL SPECIFICATION 3.6.3 COMPLIANCE WITH ONE OR MORE MAIN STEAM ISOLATION VALVES INOPERABLE |
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| By letter dated March 11, 2013 (Agencywide Documents Access and Management System Accession Number ML13070A391), | | By letter dated March 11, 2013 (Agencywide Documents Access and Management System Accession Number ML13070A391), Region III, Division of Reactor Projects, requested assistance from the Office of Nuclear Reac tor Regulation (NRR) in answering the following questions regarding the requirements for compliance with Technical Specification (TS) 3.6.3, "Containment Isolation Valves," for the Main Steam Isolation Valves (MSIVs) at Braidwood |
| Region III, Division of Reactor Projects, requested assistance from the Office of Nuclear Reac tor Regulation (NRR) in answering the following questions regarding the requirements for compliance with Technical Specification (TS) 3.6.3, "Containment Isolation Valves," for the Main Steam Isolation Valves (MSIVs) at Braidwood | |
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| ==1.0 INTRODUCTION== | | ==1.0 INTRODUCTION== |
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| By letter dated March 11, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML13070A391), | | By letter dated March 11, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML13070A391), Region III (RIII), Division of Reactor Projects, requested assistance from the Office of Nuclear Reactor Regulation (NRR) in answering the following questions regarding the requirements for compliance with Technical Specification (TS) 3.6.3, "Containment Isolation Valves," for the Main Steam Isolation Valves (MSIVs) at |
| Region III (RIII), Division of Reactor Projects, requested assistance from the Office of Nuclear Reactor Regulation (NRR) in answering the following questions regarding the requirements for compliance with Technical Specification (TS) 3.6.3, "Containment Isolation Valves," for the Main Steam Isolation Valves (MSIVs) at | |
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| Braidwood Station (Braidwood): | | Braidwood Station (Braidwood): |
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| The RIII inspectors identified an Unresolved Item related to the licensee's position that although the Unit 1 and Unit 2 MSIVs were classified as CIVs, they were not subject to TS 3.6.3, "Containment Isolation Valves," requirements. | | The RIII inspectors identified an Unresolved Item related to the licensee's position that although the Unit 1 and Unit 2 MSIVs were classified as CIVs, they were not subject to TS 3.6.3, "Containment Isolation Valves," requirements. |
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| On May 30, 2012, with Unit 1 operating at full power, the licensee declared the Unit 1A MSIV inoperable in accordance with TS 3.7.2, "Main Steam Isolation Valves (MSIVs)," during maintenance that temporarily removed both the active and standby 1A MSIV accumulators from service. | | On May 30, 2012, with Unit 1 operating at full power, the licensee declared the Unit 1A MSIV inoperable in accordance with TS 3.7.2, "Main Steam Isolation Valves (MSIVs)," during maintenance that temporarily removed both the active and standby 1A MSIV accumulators from service. |
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| The inspectors questioned why the licensee had not entered TS 3.6.3, "Containment Isolation Valves," since: 1) the MSIVs were identified in the Updated Final Safety Analysis Report (UFSAR) as CIVs; 2) the MSIVs met the GDC-57, "Closed System Isolation Valves," definition for CIVs; and 3) TS 3.6.3.C specifically addressed penetration flow paths with only one CIV in a closed system. Specifically, TS 3.6.3, "Containment Isolation Valves," stated, in part, the following: | | The inspectors questioned why the licensee had not entered TS 3.6.3, "Containment Isolation Valves," since: 1) the MSIVs were identified in the Updated Final Safety Analysis Report (UFSAR) as CIVs; 2) the MSIVs met the GDC-57, "Closed System Isolation Valves," definition for CIVs; and 3) TS 3.6.3.C specifically addressed penetration flow paths with only one CIV in a closed system. Specifically, TS 3.6.3, "Containment Isolation Valves," stated, in part, the following: |
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Category:Memoranda
MONTHYEARML23044A3662023-02-15015 February 2023 Calendar Year 2022 Reactor Oversight Process Baseline Inspection Program Completion - Region III ML22300A0842022-11-10010 November 2022 Pressure and Temperature Limits Report (Ptlr), Revision 8 ML21349A1062021-12-15015 December 2021 Justification for the Deviation from MRP 2019-008, Technical Evaluation 635273 ML21277A2472021-11-0505 November 2021 Notification of Significant Licensing Action - Proposed Issuance of Order Approving the Transfer of Licenses for Which a Hearing Has Been Requested - Exelon Generation Company, LLC; Et. Al ML20155K6862020-11-23023 November 2020 Memo to File: Environmental Assessment and Finding of No Significant Impact and NRC Financial Analysis for Exelon Corporation LLC Decommissioning Funding Plan Submitted in Accordance with 10 CFR 72.30(b) and (C) for Braidwood ISFSI ML17335A0442017-12-0404 December 2017 Tvel Lead Test Assembly 3rd Closed Meeting ML17142A2382017-05-25025 May 2017 OEDO-17-00280 - Briefing Package for Drop-In Visit on June 9, 2017, by Senior Management of Exelon Generation Company, LLC with Chairman Svinicki, Commissioner Baran, and Commissioner Burns ML16236A2022016-08-24024 August 2016 Backfit Appeal Review Panel Findings Associated with Byron and Braidwood Compliance ML16088A2042016-03-28028 March 2016 Memo T Bowers from s Ruffin, Technical Assistance Requests - Review 2015 Tri-Annual Decommissioning Funding Plans for Multiple Independent Spent Fuel Storage Installations W/ Encl 2 (Template) ML16088A2052016-03-28028 March 2016 Enclosure 1 - (72.30 DFP Reviews to Be Completed 2015) - Memo T Bowers from s Ruffin, Technial Assistance Requests - Review 2015 Tri-Annual Decommissioning Funding Plans for Multiple Independent Spent Fuel Storage Installations ML16082A5422016-03-25025 March 2016 Backfit Review Panel Recommendation Regarding Exelon Appeal of Backfit Affecting Braidwood and Byron Stations Regarding Compliance with 10 CFR 50.34(b), GDC 15, GDC 21, GDC 29, and the Licensing Basis ML16074A3232016-03-21021 March 2016 Forthcoming Meeting with Exelon Nuclear ML16075A3292016-03-16016 March 2016 OEDO-16-00165 - Briefing Package for Drop-In Visit on March 23, 2016, by Senior Management of Exelon Generation Company, LLC with the NRC Executive Director for Operations ML16070A3622016-03-15015 March 2016 03/07/2016 Summary of Public Meeting Between U.S. Nuclear Regulatory Commission Staff and Exelon Generation Company, LLC to Discuss an Appeal of a Compliance Backfit ML15336A0172016-01-20020 January 2016 Renewal of Full-Power Operating License for Braidwood Station, Units 1 and 2 ML15355A0812016-01-12012 January 2016 Backfit Review Panel Charter Regarding December 8, 2015, Exelon Appeal of Imposed Backfit Affecting Braidwood and Byron Stations ML15253A9132015-09-11011 September 2015 ACRS Full Committee - Corrections to the Aging Management Programs Table ML15187A3272015-07-13013 July 2015 Request for ACRS Review of Byron Braidwood SER ML15051A3612015-03-0303 March 2015 02/05/2015 Summary of Telephone Conference Call No 2 Held Between the NRC and Exelon Generation Co., LLC Concerning Request for Additional Information, Set 45, Pertaining to the Byron, and Braidwood, License Renewal Application ML14317A5432014-11-17017 November 2014 Federal Register Notice Regarding the ACRS Plant License Renewal Subcommittee Meeting (Braidwood/Byron), December 3, 2014 ML14205A5752014-08-11011 August 2014 Summary of Telephone Conference Call Held on June 10, 2014, Between U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC Concerning Fire Water System Request for Additional Information Responses Pertaining to Byron Station. ML14227A1092014-07-0909 July 2014 Bryron, Units 1 & 2 - Imposition of Facility-Specific Baskfit Compliance with Licensing Basis Plant Design Requirements ML14177A4302014-07-0202 July 2014 06/23/2014 Summary of Telephone Conference Call Between NRC and Exelon Generation Co., LLC, Concerning the Byron and Braidwood, License Renewal Application (TAC Nos. MF1879, MF1880, MF1881 and MF1882) ML14148A3882014-06-0505 June 2014 Summary of Telephone Conference Call Held on May 19, 2014, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC Concerning Draft Request for Additional Information, Set 28, Pertaining to the Byron Station and Br ML14126A5432014-05-19019 May 2014 Summary of Telephone Conference Call Held on April 22, 2014, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC Concerning Draft Request for Additional Information, Set 24, Pertaining to the Byron Station and ML14092A4402014-05-14014 May 2014 Summary of Telephone Conference Call Held on March 19, 2014, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC Concerning Draft Request for Additional Information, Set 18, Pertaining to the Byron Station and ML14107A2262014-05-14014 May 2014 Summary of Telephone Conference Call Held on March 26, 2014, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC Concerning Draft Request for Additional Information, Set 21, Pertaining to the Byron Station and ML14085A1102014-04-30030 April 2014 Summary of Telephone Conference Call Held on March 24, 2014 Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC, Concerning Requests for Additional Information Pertaining to the Braidwood Station, License Renew ML14092A3562014-04-15015 April 2014 Summary of Telephone Conference Call Held on March 31, 2014 Between the U.S. NRC and Exelon Generation Company, LLC, Concerning Requests for Additional Information Pertaining to the Braidwood Station, License Renewal Application ML14069A3372014-04-0202 April 2014 Final Response to Task Interface Agreement 2012-13, Braidwood Station Technical Specification 3.6.3 Compliance with One or More Main Steam Isolation Valves Inoperable ML12194A5002014-03-31031 March 2014 Final TIA Response Byron Braidwood Single Spurious Assumption ML14064A4032014-03-11011 March 2014 Summary of Telephone Conference Call on February 27, 2014, Between U.S. Nuclear Regulatory Commission & Exelon Generation Company, LLC Concerning Draft Request for Additional Information Re Byron Station & Braidwood Station License Renewal ML14058B1802014-03-11011 March 2014 Summary of Telephone Conference Call on February 18, 2014, Between U.S. Nuclear Regulatory Commission & Exelon Generation Company, LLC Concerning Draft Request for Additional Information Regarding Byron & Braidwood Stations, License Renewal ML14036A3102014-03-0404 March 2014 Summary of Telephone Conference Call Held on January 28, 2014, Between NRC and Exelon, Concerning RAI Set 10, for the Byron and Braidwood Station, LRA ML14063A1742014-01-28028 January 2014 Making Non-Concurrence NCP-2013-014 Public Available ML13267A0802013-12-0909 December 2013 Reactor Systems Branch Safety Evaluation Input to Byron Station Units 1 and 2 and Braidwood Station Units 1 and 2 Measurement Uncertainty Recapture Power Update ML13303B4632013-11-25025 November 2013 Summary of Telephone Conference Call Held on October 22, 2013, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC, Concerning RAI Set 3 for the Byron-Braidwood LRA ML13246A4342013-09-27027 September 2013 09/28/2013 Meeting Summary of Public Scoping Meetings Conducted Related to the Review of the Braidwood Station, Unit 1 and 2, License Renewal Application ML13246A0162013-09-0404 September 2013 Notice of Forthcoming Teleconference Meeting with Exelon Generation Company, LLC to Discuss Future Submittal of License Amendment Request to Clarify Braidwood Nuclear Station Technical Specification 5.5.16 ML13193A3612013-08-0505 August 2013 08/21/2013 Forthcoming Meeting to Discuss the License Renewal Process and Environmental Scoping for Exelon Generation Company, LLC, Braidwood Nuclear Station Units 1 and 2 ML13190A3522013-07-10010 July 2013 Notice of Forthcoming Teleconference with Exelon Generation Company, LLC ML13094A0922013-04-0404 April 2013 Notice of Forthcoming Meeting with Exelon Generation Company, LLC to Discuss Future Submittal of a License Amendment Request to Modify Technical Specifications for the Main Steam Isolation Valves & Their Actuators ML13014A7652013-02-0404 February 2013 03/20/2013 Notice of Forthcoming Meeting with Exelon Corporation Regarding License Renewal Application for the Byron and Braidwood Nuclear Power Stations ML12348A6962012-12-17017 December 2012 1/3/2013 - Notice of Forthcoming Meeting with Exelon Generation Company, LLC, to Discuss Requests for Additional Information Regarding Exelon Physical Security Plans ML1208602902012-03-26026 March 2012 Notice of Forthcoming Public Meeting with Exelon Generation to Discuss Future Fleet Submittal Regarding Licensed Operator Eligibility Requirements ML1120104142011-07-21021 July 2011 Staff Review of Braidwood Nuclear Power Plant Independent Spent Fuel Storage Installation Physical Security Plan and Verification of ASM Incorporation ML1110906502011-05-0505 May 2011 Notice of Forthcoming Meeting with Exelon Generation Company, LLC Pre-Application Meeting to Discuss Proposed Amendment Uncertainty Recapture (Mur) Power Uprate License Amendment Request for Braidwood Station, Units 1 & 2 and Byron, Units 1 ML11132A1292011-03-17017 March 2011 Transmittal of Ihpb Safety Evaluation, Byron, Units 1 and 2, Braidwood, Units 1 and 2, License Amendment Request Regarding Low Temperature Overpressure Protection and Loss of Decay Heat Removal ML1100502522011-02-0909 February 2011 Memo to Chairman Jaczko Fm R. W. Borchardt, EDO Initiatives for Improved Communication of Groundwater Incidents ML1030702392010-11-0303 November 2010 Notice of Category 3 Public Meeting NRC Roundtable Discussion with NRC Commissioner William Magwood, IV 2023-02-15
[Table view] Category:Task Interface Agreement Response (TIA)
MONTHYEARML14069A3372014-04-0202 April 2014 Final Response to Task Interface Agreement 2012-13, Braidwood Station Technical Specification 3.6.3 Compliance with One or More Main Steam Isolation Valves Inoperable ML12194A5002014-03-31031 March 2014 Final TIA Response Byron Braidwood Single Spurious Assumption 2014-04-02
[Table view] Category:Technical Specifications
MONTHYEARML23087A0762023-07-13013 July 2023 Issuance of Amendment Nos. 232 and 232 Revision of Technical Specifications for the Ultimate Heat Sink RS-23-052, License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2023-03-24024 March 2023 License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink ML22095A2702022-05-12012 May 2022 Issuance of Amendment Nos. 227, 227, 229, 229, and 245, Respectively, Regarding Adoption of TSTF 273, Safety Function Determination Program Clarifications ML22090A0862022-04-29029 April 2022 Amendments to Adopt TSTF-541,Rev.2,Add Exceptions to Surveillance Requirements for Valves,Dampers Locked in Actuated Position RS-22-049, Constellation Energy Generation, LLC, Supplemental Information to Correct Typographical Errors in Constellation'S Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for2022-04-0404 April 2022 Constellation Energy Generation, LLC, Supplemental Information to Correct Typographical Errors in Constellation'S Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for V ML21347A0382022-01-13013 January 2022 Issuance of Amendments to Revise Reactor Coolant Leakage Requirements JAFP-21-0089, Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position2021-09-27027 September 2021 Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position ML21154A0462021-07-13013 July 2021 Issuance of Amendments Nos. 222 and 222 Revision of Technical Specifications for the Ultimate Heat Sink ML21060B2812021-04-0202 April 2021 Issuance of Amendments Nos. 221, 221, 224, and 224 Regarding Technical Specifications 3.8.1, AC Sources-Operating ML20317A0012020-12-28028 December 2020 Non-Proprietary, Issuance of Amendment Nos. 219, 219, 223, and 223, Revise Loss-of-Coolant Accident Methodology in TS 5.6.5, Core Operating Limits Report (COLR) ML21008A4052020-12-17017 December 2020 Byron/Braidwood Stations - Revision 18 to Updated Final Safety Analysis Report, Chapter 16, Technical Specifications RS-20-154, Application for Revision to TS 5.5.9, Steam Generator (SG) Program for a One-Time Deferral of Steam Generator Tube Inspections2020-12-16016 December 2020 Application for Revision to TS 5.5.9, Steam Generator (SG) Program for a One-Time Deferral of Steam Generator Tube Inspections ML20167A0072020-09-11011 September 2020 R. E. Ginna - Issuance of Amendment Nos. 216, 216, 220, 220, and 143 - Adoption of TSTF-567, Rev. 1, Add Containment Sump Technical Specifications to Address GSI-191 Issues ML20118C4292020-06-0909 June 2020 Issuance of Amendments Revision of Technical Specifications for the Ultimate Heat Sink ML20086M2882020-04-0202 April 2020 Correction of Amendments Nos. for Amendments Revising Instrument Testing and Calibration Definitions RS-19-115, Supplement to Application to Revise Braidwood Station and Byron Station Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2019-12-20020 December 2019 Supplement to Application to Revise Braidwood Station and Byron Station Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b ML19190A0812019-08-28028 August 2019 Issuance of Amendments Regarding Limiting Condition of Operation for Inoperability of Snubbers RS-19-018, Supplement to Application to Revise Technical Specifications to Adopt Risk Informed Completion Times2019-02-14014 February 2019 Supplement to Application to Revise Technical Specifications to Adopt Risk Informed Completion Times ML18067A1812018-06-0404 June 2018 Correction to Technical Specification Amendment Identification Format ML16180A2512016-08-0101 August 2016 Issuance of Amendments Regarding Use of Optimized Zirlo as Fuel Cladding Material ML16133A4382016-07-26026 July 2016 Issuance of Amendments Ultimate Heat Sink Temperature Increase RS-16-034, License Amendment Request and 10 CFR 50.12 Exemption Request for the Use of Optimized Zirlo Fuel Rod Cladding2016-02-23023 February 2016 License Amendment Request and 10 CFR 50.12 Exemption Request for the Use of Optimized Zirlo Fuel Rod Cladding ML15336A7312016-01-27027 January 2016 TS 50456-Bwd-AppsABC ML15307A7762015-12-21021 December 2015 Braidwood - Issuance of Amendments Regarding Installation of New Low Degraded Voltage Relays and Timers on the 4.16 Kv Engineered Safety Features (ESF) Buses (CAC Nos. MF4051 - MF4054) ML15341A3162015-12-14014 December 2015 Correction of Technical Specifications Related to Amendment 145 ML15286A2762015-11-19019 November 2015 Technical Specifications ML15232A4412015-10-28028 October 2015 Issuance of Amendments to Utilize WCAP-16143-P, Revision 1 Reactor Vessel Closure Head/Vessel Flange Requirements Evaluation for Byron/Braidwood Units 1 and 2, Dated October 2014 ML15268A4862015-10-0606 October 2015 Correction of Amendments Adopting Technical Specification Task Force Traveler TSTF-523 (TAC Nos. MF4436-MF4446) ML15141A0582015-07-28028 July 2015 Issuance of Amendments Regarding Emergency Action Level Schemes (TAC Nos. MF4232-MF4251) ML14323A5222015-04-0808 April 2015 Issuance of Amendments Regarding the Emergency Plan Definition of Annual Training RS-14-337, Units 1 & 2 - License Amendment Request for Diesel Generator Load Rejection Surveillance Requirement2014-12-18018 December 2014 Units 1 & 2 - License Amendment Request for Diesel Generator Load Rejection Surveillance Requirement ML14239A4272014-12-0707 December 2014 Issuance of Amendments to Clarify Technical Specification 3.3.1, Reactor Trip System Instrumentation, and TS 3.3.2, Engineered Safety Feature Actuation System Instrumentation ML13311B4812014-07-21021 July 2014 Issuance of Amendments to Revise Technical Specifications Section 3.5.3 ML14085A5322014-07-21021 July 2014 Issuance of Amendments Adoption of TSTF-522 Ventilation System Surveillance Requirements ML14069A3372014-04-0202 April 2014 Final Response to Task Interface Agreement 2012-13, Braidwood Station Technical Specification 3.6.3 Compliance with One or More Main Steam Isolation Valves Inoperable ML13326A1072014-03-13013 March 2014 Issuance of Amendments to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program ML13281A0002014-02-0707 February 2014 Issuance of Amendments Regarding Measurement Uncertainty Recapture Power Uprate RS-13-240, License Amendment Request to Administratively Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program.2013-10-10010 October 2013 License Amendment Request to Administratively Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program. RS-13-137, Application to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month, Using the Consolidated Line Item Improvement Process2013-09-0303 September 2013 Application to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month, Using the Consolidated Line Item Improvement Process RS-13-175, Bryon, Units 1 and 2, License Amendment Request to Revise Technical Specifications Section 3.7.2, Main Steam Isolation Valves (Msivs).2013-08-21021 August 2013 Bryon, Units 1 and 2, License Amendment Request to Revise Technical Specifications Section 3.7.2, Main Steam Isolation Valves (Msivs). RS-12-009, License Amendment Request - Diesel Generator Steady State Maximum Frequency and Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel2012-05-0101 May 2012 License Amendment Request - Diesel Generator Steady State Maximum Frequency and Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel RS-12-028, Application to Revise Technical Specifications to Adopt TSTF-510, Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection.2012-03-22022 March 2012 Application to Revise Technical Specifications to Adopt TSTF-510, Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection. RS-12-023, License Amendment Request to Revise Tech Specs Sections 5.5.9, Steam Generator (SG) Program, and TS 5.6.9, Steam Generator (SG) Tube Inspection Report, for Permanent Alternate Repair Criteria2012-03-20020 March 2012 License Amendment Request to Revise Tech Specs Sections 5.5.9, Steam Generator (SG) Program, and TS 5.6.9, Steam Generator (SG) Tube Inspection Report, for Permanent Alternate Repair Criteria RS-11-136, Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications (TS) 3.3.12011-09-0202 September 2011 Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications (TS) 3.3.1 ML1117900312011-06-23023 June 2011 Request for License Amendment Regarding Measurement Uncertainty Recapture (Mur) Power Uprate, Attachment 2A, Markup of Proposed Operating License and Technical Specifications Pages ML1032704352010-12-21021 December 2010 Tech Spec Pages for Braidwood and Byron Amendment Large Break Loss-of-Coolant Accident Analysis Using Astrum ML1032704452010-12-21021 December 2010 Tech Spec Pages for Braidwood and Byron Amendment Large Break Loss-of-Coolant Accident Analysis Using Astrum RS-10-197, License Amendment Request to Revise Technical Specifications (TS) Sections 5.5.9, Steam Generator Program, and TS 5.6.9, Steam Generator Tube Inspection Report, for Temporary Alternate Repair Criteria2010-12-14014 December 2010 License Amendment Request to Revise Technical Specifications (TS) Sections 5.5.9, Steam Generator Program, and TS 5.6.9, Steam Generator Tube Inspection Report, for Temporary Alternate Repair Criteria RS-10-114, License Amendment Request Regarding Low Temperature Overpressure Protection and Loss of Decay Heat Removal2010-06-29029 June 2010 License Amendment Request Regarding Low Temperature Overpressure Protection and Loss of Decay Heat Removal RS-10-052, License Amendment Request for an Extension of the Inspection Interval for Reactor Coolant Pump Flywheels Using the Consolidated Line Item Improvement Process2010-03-29029 March 2010 License Amendment Request for an Extension of the Inspection Interval for Reactor Coolant Pump Flywheels Using the Consolidated Line Item Improvement Process 2023-07-13
[Table view] |
Text
April 2, 2014
MEMORANDUM TO: Kenneth G. O'Brien, Deputy Director Division of Reactor Projects Region III
FROM: Sher Bahadur, Deputy Director /RA/ Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
SUBJECT:
FINAL RESPONSE TO TASK INTERFACE AGREEMENT 2012-13, BRAIDWOOD STATION TECHNICAL SPECIFICATION 3.6.3 COMPLIANCE WITH ONE OR MORE MAIN STEAM ISOLATION VALVES INOPERABLE
By letter dated March 11, 2013 (Agencywide Documents Access and Management System Accession Number ML13070A391), Region III, Division of Reactor Projects, requested assistance from the Office of Nuclear Reac tor Regulation (NRR) in answering the following questions regarding the requirements for compliance with Technical Specification (TS) 3.6.3, "Containment Isolation Valves," for the Main Steam Isolation Valves (MSIVs) at Braidwood
Station (Braidwood):
- 1. With one or more Braidwood Unit 1 or Unit 2 MSIVs inoperable and open is the licensee required to enter TS 3.6.3.C? 2. With one or more of the following General Design Criteria (GDC)-57, TS 3.6.3.C Closed System Containment Isolation Valves (CIVs) inoperable and open would the licensee be required to enter TS 3.6.3.C? a. Main Steam Isolation Valve Bypass Valve (i.e., MS101 valves); b. Main Steam Generator [(SG)] Power Operated Relief Valves
[(PORVs)] (i.e., MS018 valves); or c. Main Feedwater Isolation Valves (i.e., FW009 valves). 3. If the answer to Question #1 is "No"; and Question #2 is "Yes", explain the basis for the difference, including a discussion of Mode 4 applicability.
The NRR staff have reviewed Technical Interface Agreement 2012-13 and find the following:
TS 3.6.3 is applicable and needs to be entered when any one becomes inoperable; in addition to TS 3.6.3, TS 3.7.4 is applicable when a SG PORV becomes inoperable; Braidwood's current licensing bases is consistent with the original licensing bases for the plant, and the MSIVs are not applicable to TS 3.6.3, CIVs. This position is documented in the enclosed evaluation.
Enclosure:
As stated
CONTACT: Holly D. Cruz, DPR/PLPB (301) 415-1053
ML14069A337;*No significant changes from Draft TIA Response. NRR-106 OFFICE DPR/PLPB/PM DPR/PLPB/LA* DSS/SCVB* DSS/STSB* DPR/PLPB* DPR/DD NAME HCruz DBaxley RDennig RElliott AMendiola SBahadur DATE 04/02/2014 08/29/2013 07/15/2013 07/19/2013 10/04/2013 04/02/2014 ENCLOSURE TASK INTERFACE AGREEMENT 2012-13, BRAIDWOOD STATION TECHNICAL SPECIFICATION 3.6.3 COMPLIANCE WITH ONE OR MORE MAIN STEAM ISOLATION VALVES INOPERABLE
1.0 INTRODUCTION
By letter dated March 11, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML13070A391), Region III (RIII), Division of Reactor Projects, requested assistance from the Office of Nuclear Reactor Regulation (NRR) in answering the following questions regarding the requirements for compliance with Technical Specification (TS) 3.6.3, "Containment Isolation Valves," for the Main Steam Isolation Valves (MSIVs) at
Braidwood Station (Braidwood):
- 1. With one or more Braidwood Unit 1 or Unit 2 MSIVs inoperable and open is the licensee required to enter TS 3.6.3.C? 2. With one or more of the following General Design Criteria (GDC)-57, TS 3.6.3.C Closed System Containment Isolation Valves (CIVs) inoperable and open would the licensee be required to enter TS 3.6.3.C? a. Main Steam Isolation Valve Bypass Valve (i.e., MS101 valves); b. Main Steam Generator Power Operated Relief Valves (i.e., MS018 valves); or c. Main Feedwater Isolation Valves (i.e., FW009 valves). 3. If the answer to Question #1 is "No"; and Question #2 is "Yes", explain the basis for the difference, including a discussion of Mode 4 applicability.
The NRR staff's assessment is provided in this enclosure.
2.0 BACKGROUND
The RIII inspectors identified an Unresolved Item related to the licensee's position that although the Unit 1 and Unit 2 MSIVs were classified as CIVs, they were not subject to TS 3.6.3, "Containment Isolation Valves," requirements.
On May 30, 2012, with Unit 1 operating at full power, the licensee declared the Unit 1A MSIV inoperable in accordance with TS 3.7.2, "Main Steam Isolation Valves (MSIVs)," during maintenance that temporarily removed both the active and standby 1A MSIV accumulators from service.
The inspectors questioned why the licensee had not entered TS 3.6.3, "Containment Isolation Valves," since: 1) the MSIVs were identified in the Updated Final Safety Analysis Report (UFSAR) as CIVs; 2) the MSIVs met the GDC-57, "Closed System Isolation Valves," definition for CIVs; and 3) TS 3.6.3.C specifically addressed penetration flow paths with only one CIV in a closed system. Specifically, TS 3.6.3, "Containment Isolation Valves," stated, in part, the following:
LCO [Limiting Condition for Operation] 3.
6.3 Each containment isolation valve shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
CONDITION REQUIRED ACTION COMPLETION TIME C. ---------Note---------- Only applicable to penetration flow paths with only one containment isolation valve and a closed system.
One or more penetration flow paths with one containment isolation valve inoperable.
C.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic or remote manual valve, closed manual valve, or blind flange. AND C.2 ------NOTES---- 1. Isolation devices in high radiation areas may be verified by use of administrative means.
- 2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means. ------------------------
Verify the affected penetration flow path is isolated.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
Once per 31 days
The inspectors discussed this question with the licensee staff and management. When evaluating TS 3.6.3 applicability prior to the maintenance activity, Operations referred to Table B 3.6.3-1, "Primary Containment Isolation Valves," in the TS 3.6.3 Bases. The MSIVs were not listed in this table, therefore, Operations concluded that TS 3.6.3 was not applicable. The licensee entered the inspectors' question into its corrective action program and evaluated the issue in more detail by reviewing the origin of the TS 3.6.3 Bases table, re-reviewed the current licensing basis, and conducted an independent review led by corporate licensing engineers to determine if TS 3.6.3 should be applicable to the MSIV CIVs. In addition, the licensee contacted other reactor licensees to gain additional insights.
3.0 EVALUATION
Question 1: With one or more Braidwood Unit 1 or Unit 2 MSIVs inoperable and open is the licensee required to enter TS 3.6.3.C?
No the licensee is not required to enter TS 3.6.3.C for an inoperable MSIV.
Question 2a: With one or more of the following GDC-57, TS 3.6.3.C Closed System CIVs inoperable and open would the licensee be required to enter TS 3.6.3.C?
- a. MSIV Bypass Valve (i.e., MS101 valves)
Yes, if the plant is in Modes 1, 2, 3, or 4. Braidwood TS 3.6.3, "Containment Isolation Valves,"
LCO was derived from the assumptions related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during a design bases loss of coolant or rod ejection accident. CIVs form a part of the containment boundary. As part of the containment boundary, CIV operability supports leak tightness of the containment. Therefore, the safety analyses of any event requiring isolation of containment are applicable to this LCO. In Modes 1, 2, 3, and 4, a design-bases accident could cause a release of radioactive material to containment. TS 3.6.3 provides the lowest functional capability or performance levels of the CIVs which are required to mitigate a loss of reactor coolant inventory and a release of radioactive material from containment during loss of coolant or rod ejection accident.
The MSIV bypass valves are CIVs; therefore, TS 3.6.3 is applicable and needs to be entered when a MSIV bypass valves becomes inoperable.
Question 2b: With one or more of the following GDC-57, TS 3.6.3.C Closed System CIVs inoperable and open would the licensee be required to enter TS 3.6.3.C?
- b. Main Steam Generator Power Operated Relief Valves (i.e., MS018 valves)
Yes, if the plant is in Modes 1, 2, 3, or 4. As stated above in Question 2a, TS 3.6.3 provides the
lowest functional capability or performance levels of the CIVs which are required to mitigate a loss of reactor coolant inventory and a release of radioactive material from containment during loss of coolant or rod ejection accident.
Braidwood TS 3.7.4, "Steam Generator (SG) Power Operated Relief Valves (PORVs)," LCO is established by the Steam Generator Tube Rupture (SGTR) event described in UFSAR, Section 15.6.3. In addition, the SG PORVs serve as CIVs; however, the containment isolation function is addressed in TS 3.6.3. TS 3.7.4 requires the SG PORVs to be operable in Modes 1, 2, and 3. In Mode 4 the pressure and temperature limitations are such that the probability of a SGTR event requiring SG PORV operation is low. TS 3.7.4 provides the lowest functional capability or performance levels of the SG PORVs which are required to mitigate a SGTR.
TS 3.6.3 and TS 3.7.4 are each derived from different accident analyses. Each analysis has different initial conditions and mitigation strategies, therefore, each LCO provides an independent set of Conditions and Required Actions in response to the accident evaluated. Hence, both TS 3.6.3 and TS 3.7.4 are applicable and need to be entered when a SG PORV becomes inoperable.
Question 2c: With one or more of the following GDC-57, TS 3.6.3.C Closed System CIVs inoperable and open would the licensee be required to enter TS 3.6.3.C?
- c. Main Feedwater Isolation Valves (i.e., FW009 valves).
Yes, if the plant is in Modes 1, 2, 3, or 4. As stated above in Question 2a, TS 3.6.3 provides the
lowest functional capability or performance levels of the CIVs which are required to mitigate a loss of reactor coolant inventory and a release of radioactive material from containment during loss of coolant or rod ejection accident.
The main feedwater isolation valves are CIVs; therefore, TS 3.6.3 is applicable and needs to be entered when a main feedwater isolation valve becomes inoperable.
Question 3: If the answer to Question #1 is 'No,' and Question #2 is 'Yes,' explain the basis for the difference, including a discussion of Mode 4 applicability.
Braidwood's original TSs were issued on October 17, 1986 (ADAMS Accession Number ML021820378) and are contained in NUREG-1223, "Technical Specifications, Braidwood Station Unit Nos. 1 and 2, Docket Nos. STN 50-456 and STN 50-457, Appendix "A" to Licensee No. NPF-59." TS 3/4.6.3, "Containment Isolation Valves," required that the CIVs specified in Table 3.6-1 shall be operable. Table 3.6-1 listed the CIVs which among this list were: MS101D, MS101A, MS101B, MS101C, FW009D, FW009A, FW009B, FW009C, MS018D, MS018A, MS018B, and MS018C. MS001A, MS001B, MS001C, and MS001D are not included on this list, therefore, Braidwood Unit 1 and 2 were originally licensed without the MSIVs being considered CIV.
On May 6, 1991, Generic Letter 91-08 was published. This generic letter provides guidance for preparing a request for a license amendment to remove component lists from TSs. This guidance provides an acceptable alternative to identifying every component by its plant identification number as it is currently listed in the tables of TS components. The removal of component lists is acceptable because it does not alter existing TS requirements or those components to which they apply. This generic letter, along with Braidwood's conversion to improved TSs, relocated TS Table 3.6-1 from Braidwood's TS to its improved TSs Bases. The NRC staff reviewed the current CIV list that is in Braidwood's TS Bases and has determined that the list includes the same valves that were relocated from Braidwood's TS.
The NRC staff has determined that Braidwood's current licensing bases is consistent with the original licensing bases for the plant, and that the MSIVs are not applicable to TS 3.6.3, CIVs.
4.0 CONCLUSION
TS 3.6.3 provides mitigation for loss of reactor coolant inventory and a release of radioactive material from containment during loss of coolant or rod ejection accident. TS 3.7.2 provides mitigation for the various steam line breaks inside and outside containment. TS 3.7.4 provides mitigation for a SGTR. The TS LCOs stated above are derived from different accident analyses. Each analysis has different initial conditions and mitigation strategies, therefore, each LCO provides an independent set of Conditions and Required Actions in response to the accident evaluated.
The MSIV bypass valves, SG PORVs, and main feedwater isolation valves are CIVs.
Therefore, TS 3.6.3 is applicable and needs to be entered when any one becomes inoperable.
In addition to TS 3.6.3, TS 3.7.4 is applicable when a SG PORV becomes inoperable. In addition, Braidwood's current licensing bases is consistent with the original licensing bases for the plant, and that the MSIVs are not applicable to TS 3.6.3, CIVs.
Principal Contributor: Kristy Bucholtz
Date: April 2, 2014