ML20153E874

Forwards Response to NRC RAI Re 961213 Amend to Plants TS to Adopt Improved TS of NUREG-1431,Rev 1.Submittal Does Not Include Replacement of Current TS Markup Pages as Discussed with NRC in 970812 Telcon

ML20153E874
Person / Time
Site:	Byron, Braidwood
Issue date:	09/21/1998
From:	Tulon T COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-1431 NUDOCS 9809280283
Download: ML20153E874 (12)

Text

• • l e e Commonwealth I'dison Company liraidwood Generating Station Route *l. Ilox H i Ilraceville.11. N) 607-9619 l

TelHi&l582801 l

l September 21,1998 I l

United States Nuclear Regulatory Commission Attn: Document Control Desk Washington D.C. 20555 - 0001

Subject:

Commonwealth Edison's (Comed's) Response to the NRC's Request for Additional Information (RAI) for Improved Technical Specifications (ITS)

Section 3.3 Byron Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Numbers: 50-454 and 50-455 Braidwood Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-72 and NPF-77 NRC Docket Numbers: 50-456 and 50-457

References:

G. Stanley and K. Graesser (Comed) letter to USNRC, " Conversion to the Improved Standard Technical Specifications," dated December 13,1996 The purpose of this letter is to transmit Comed's Response to the NRC's RAI for ITS Section 3.3. The responses to the RAI questions are contained in the Attachment, Response to NRC RAI for ITS Section 3.3.

The RAI contains questions and comments stemming from the NRC's partial review of a Comed request (Reference 1) to amend the Current Technical Specifications (CTS) for Byron Units 1 and 2 and Braidwood Units 1 and 2. The amendments were requested in order to adopt the Improved Technical Specifications of NUREG-1431, Revision 1.

l l

C\

RO

]

9809280283 980921 DR ADOCK 050004 4 A Unicom Compan)

- - _ - . _ - - - _ . _ _. _ _ _ . _ -. _ _ _ . _ _ _ . .~.. _ _ _ _ _ _ . _ _ . .-

i U.S. NRC Document Control Desk Se'ptember 21,1998 Page 2 l

l As discussed with NRC Staffin an August 12,1997 teleconference, this submittal does

!- not include any replacement or CTS Markup pages. The required page changes and markups will be submitted at a later date when the NRC review and acceptance of Comed's Response to this NRC RAI is complete, i

l Please address any comments or questions regarding this matter to our Nuclear Licensing Department.

Sincerely, lq f Timothy J. Tulon Site Vice President l Braidwood Nuclear Generating Station

Attachment:

Response to NRC RAI for ITS Section 3.3 cc: Regional Administrator-Rill Senior Resident Inspector - Braidwood l Senior Resident Inspector - Byron Office of Nuclear Facility Safety -IDNS nrc/98058tjt. doc l

. . . _. - . . . _ _ - . = _ _ - . _ . .- ._

t Attachment l 1

Byron / Braidwood Response to NRC RAI for ITS Section 3.3 (Improved Technical Specification Submittal) l l

-t-

Response to NRC R 1 For ITS Section 3.3 17 Sep-98 NRC RAI Number NRC Issued Date RAI Status 33.1-01 9/11/98 Open Comed Action Required NRC Description of issue DOC L.26 CTS Table 33-1 Action 2.b ITS LCO 3.3.1 Condition E Discussion of Change L.26 states in one sentence that "The equivalent ITS Action . . does not require these steps" whereas in the next sentence states that "these actions are necessary " This particular CTS Action is not included in the ITS as stated j

in the first part of the CTS DOC L.26. For the mest part this change is justified. Comment: Review and revise DOC L.26 to 1 eliminate conflicting statements.

Comed Response to Issue The word "not" was inadvertently omitted in the conflicting sentence. The sentence in CTS DOC 3.3-L26 was revised to i

state, "Since the Power Range Neutron Flux Rate Functions are not influenced by the power level, and do not impact the protection related to maintaining QPTR, these actions are not necessary." This change will be provided in our comprehensive ITS Section 3.3 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.3 RAl.

NRC RAI Number NRC lssued Date RAI Status 3.3.1-02 9/11/98 Open - Comed Action Required NRC Description of Issue CTS Table 2.2.1 Functional Unit 19.a ITS Table 3.3.1-1 Function 17.a STS Table 3.3.1-1 Function 18.a O ITS Table 3.3.1 1 Note c.

V STS Table 3.3.1-1 Note d.

ITS Table 3.3.1 1 Note d.

STS Table 3.3.1-1 Note e.

The CTS references the term " Intermediate Range 1 Neutron Flux, P-6" in the Tables and in associated Notes. The corresponding P-6 in the ITS has been changed to " Source Range Block Permissive" without supporting DOC. Comments:

Provide specific DOC for the change in terminology from intermediate Range Neutron Flux P-6 to Source Range Block Permissive P-6.

Comed Response to issue In the CTS Markups, the generic CTS DOC 3.3-Al was changed to a specific CTS 'A' DOC and states, " CTS and STS use the term " Intermediate Range Neutron Flux" for the P-6 RTS interlock. In ITS, the P-6 interlock is referred to as " Source Range Block Permissive " This change was made so that the TS agree with plant design and terminology. The Byron /Braidwood Main Control Room annunciator ar' Bypass Permissive Panel windows, as well as plant procedures, reference " Source Range Block Permissive" for the i interlock. This change is considered editorial in nature and does not involve a technical change (either actual or interpretausnal) to the TS." This change will be provided in our comprehensive ITS Sectica 3.3 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.3 RAl.

= _ , --

=  ; - -- .

- . - . = - -

+

b

(

l l I i

l

, . _ ~ . _ -

RISponse to NRC RAI For ITS Section 3.3 17-Sep-98

r - . - ~ = ,=-

_:- .= = _ _ - - -

l j

NRC RAI Number NRC lssued Date RAI Status O

• v -

3.3.1-03 NRC Description ofissue 9/11/98 Open-Comed Action Required CTS Table 2.2.1 Functional Unit 19.b 1) and 2) " Allowable Value" l ITS Table 3.3.1-1 Function 17.a i STS Table 3.3.1-1 Function 18.a l

CTS Table 2.2-1 Functional Unit 19.a items 1) and 2) Allowable Values is not retained in the ITS. There is no DOC to l support the deletion of these items. Comment: Revise submittal to either include these Allowable Values in the ITS or l provide DOC to support the deletion.

Comed Response to Issue An 'A' DOC was written and states, " CTS Table 2.2-1 for Functional Unit 19.b (P-7) lists the inputs into P-7, namely Functional Unit 19.b.I (P-10) and Functional Unit 19.b.2 (P 13). Functional Unit 19.b.i and Functional Unit 19.b.2 have l been deleted since they are redundant to CTS Table 2.2-1 Functional Units 19.d (P-10) and 19.e (P-13). The Allowable l Values in CTS Table 2.2-1 for Functional Unit 19.d and Functional Unit 19.e have been retained in ITS Table 3.3.1 1 for Function 17.d (P-10) and Function 17.e (P-13). During this reformatting, no technical changes (either actual or j l

interpretational) were made to the TS unless they were identified andjustified. The change is consistent with NUREG- l 1431." This change will be provided in our comprehensive ITS Section 3.3 closeout submittal revision upon NRC's l

concurrence with the Comed Responses to the ITS Section 3.3 RAl. I

_.-.-_-.=.;_ . .- - . = = . = . _ _ -. . - -

l NRC RAI Number NRC Issued Date RAI Status 1

3.3.1-04 9/l1/98 Open-Comed Action Required NRC Description ofIssue CTS Table 2.t.. Note !

ITS Table 3.3.1-1 Note 1 C STS Table 3.3.1-1 Note 1 Item P' in the CTS Table 2.2.1 Note 1 is defined by using the "=" sign. The same item in the ITS Table 3.3.1-1 Note I is defined by using the "" with no supporting DOC. Comment: Revise submittal to either include the "=" in the ITS or provide DOC to support the change.

Comed Response to Issue The " greater than or equal to" sign for P' in ITS Table 3.3.1-1 was changed to the " equal" sign, consistent with Current l

Licensing Basis in CTS Table 2.2-1. This change will be provided in our comprehensive ITS Section 3.3 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.3 RAl.

, ; _ -z = : =- = -_: = = -

1

[D G'

2

e .

! Response to NRC RAI For ITS Szetion 3.3 17-Sep-98 i z . . .  : -: = = - -- . . _ . . .

NRC RAI Number NRC Issued Date RAI Status

' , 3.3. t-05 9/11/98 Open Comed Action Required i NRC Description ofissue l CTS Table 4.3-1 Functional Unit 17 and 18 ITS Table 3.3.1-11 unction 11 and 16 CTS Table 4.3 1 Note 10 ITS SR 3.3.1.13 Note 1 STS SR 3.3.1.14 Note The Note in the ITS SR 3.3.1.13 which states that " Verification of setpoint is not required" is not used in the CTS SR. CTS Table 4.3-1 Functional Unit 17 and 18 does not reference CTS Table 4.3-1 Note 10 which in other cases would provide exception to the verification of setpoints. There is no DOC to support this less restrictive change. Comment: Revise submittal to provide DOC to support this less restrictive change.

Comed Response to issue An 'U DOC was written and states, " CTS Table 4 3-1 for Functional Units I,17, and 18 for Manual Reactor Trip, Si input from ESF, and RCP Breaker Position Trip, respectively, requires a TADOT be performed every refueling. ITS has added a l

Note to SR 3.3.1.13, the 18 month TADOT, to exclude verification of setpoints from the TADOT. This change is acceptable i since the affected Functions have no setpoints associated with them. This change is consistent with NUREG-1431." This l change will be provided in our comprehensive ITS Section 3.3 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.3 RAI.

= _ = = - - - - - -- -

NRC RAI Number NRC issued Date RAI Status 3.3.1-06 9/11/98 Open-Comed Action Required NRC Description of issue b DOC A.11

( CTS SR 4.3.1.2 ITS Table 3.3.1-1 Function 2.a,2.b,3.b,5,6,7,8.a,8.b,10,12,13, and 14 ITS SR 3.3.1.15 Note l

STS SR 3.3.1.16 Note The Note in the ITS SR 3.3.1.15 which states that " Neutron detectors are excluded from response time testing" is not used in the CTS SR 4.3.1.2. DOC A.! 1, CTS Table 4.3 1 Functional Units or CTS Table 4.3-1 Table Notations do not provide exceptions to Neutron detection response time testing. There is no DOC to support this less restrictive change. Comment:

Revise submittal to provide DOC to support this less restrictive change.

Comed Response to issue An 'L' DOC was written and states, " CTS SR 4.3.1.2 requires a Response Time test be performed at least once per 18 months for each reactor trip function. ITS has added a Note to SR 3.3.1.15, the 18 month staggered RTS Response Time surveillance, to exclude the neutron detectors from response time testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal. Excluding the detectors is acceptable because the principles ofdetector operation ensure a virtually instantaneous response. This change is consistent with NUREG 1431." This change will be provided in our comprehensive ITS Section 3.3 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.3 RAl.

_ =- _ . _ - - _. _ _ - - - - -

l O

V 3

l

~

_ .[ ,.2'C 7, I 'i.'"^[~[

-'l 1-' ,

Rzsponse to NRC RAI For ITS Section 3.3 17-Sep 98 N'RC RAI Numl$er NRC lssued ble RAI Status 3.3. bO7 9/11/98 Open - NRC Action Required

%.)

NRC Description of Issue JFD C.7 ITS BASES SR 3.3.1.15 Insert B 3.3-59A l

ITS BASES SR 3.3.2.11 Insert B 3.3-il9A STS BASES SR 3.3.1.16 STS BASES SR 3.3.2.10 The ITS BASES for SR 3.3.1.15 and SR 3.3.2.11 have adopted TSTF-111. At this time, TSTF-111 has not been approved by the NRC and, in addition, insert B 3.3-59A and insert B 3.3 119A for the ITS does not contain the latest information discussions / revisions. These latest revisions relating to TSTF 111 are addressed in a memo from Dr. W. Beckner (NRC) to Mr. Davis (NEI) dated 17 August 1998. Comment: Revise submittal to either use the STS without TSTF 111 or adopt TSTF-l i l (with the latest revisions) with the assumption that it (TSTF-I l l) will be adopted by the industry prior to issuance of COMED's TS amendment SE.

Comed Response to Issue No change. Comed has adopted TSTF-111, Revision 0, which was approved by the NRC on March 13,1997. Comed is aware of the William Becker (NRC) to Mr. Davis (NEI) letter dated August 17,1998 dispositioning changes to the STS made by the NEl Technical Specification Task Force (TSTF). The disposition of TSTF il 1, Revision 1, was " modify."

Comed has reviewed proposed TSTF-ill, Revision 2, and has found that it conflicts with the August 17,1998 letter.

i Therefore, until these difTerences are resolved and a subsequent revision of TSTF 111 approved, Comed continues to pursue the changes associated with NRC approved TSTF-l l 1, Revision 0 (Bases JFD 3.3-C7).

NRC RAI Number NRC Issued Date RAI Status 3.3.3-01 9/11/98 Open - Comed Action Required NRC Description ofissue JFD P26 ITS 3.3.3, PAM instrumentation ITS Table 3.3.3 1 The proposed ITS 3.3.3 PAM TS needs to be revised. Specifically, the following areas need to be modified:

1) The proposed Condition A is not general enough to encompass all of the conditions in Table 3.3.3-1. Suggest that Condition A be revised, similar to Condition A in TS 3.3.1 and TS 3.3.2, to read: "One or more functions with one or more required channels inoperable."

2) Proposed Condition B should read as proposed Condition A currently reads.

3) The Note to Condition E, declaring it not applicable to Function 15, is incorrectly discussed in the Bases as being a Note to Condition D.

Comment: Revise the submittal.

Comed Response to issue item a: ITS LCO 3.3.3 Condition A will be revised, similar to Condition A in ITS LCO 3.3.1 and ITS LCO 3.3.2, to read, "One or more functions with one or more required channels inoperable."

Item c: On page B 3.3-135 in the Bases Markups, the ACTIONS Section of the Bases for ITS LCO 3.3.3 (Actions D.1 and E.1) will be revised to state, " Condition E is modified by a Note that excludes hydrogen monitor channels." These changes will be provided in our comprehensive 11S Section 3.3 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.3 RAI.

Item b: No change. Comed disagrees that the proposed Condition B should read as the proposed (old) Condition A currently reads. The new Condition A will read, "One or more functions with one or more required channels inoperable."

The new Condition A will encompass the old Condition A, and therefore the old Condition A does not need to be changed to

, O Condition B. This is consistent with ITS LCOs 3.3.1 and 3.3.2. Comed continues to pursue this change.

f t

4

= . = = = = . , _=_

Response to NRC RAI For ITS Section 3.3 17-Sep-98 1

.;- = . .

j NRC RAI Number NRC Issued Date RAI Status i

, 3.3.4-01 9/11/98 Open-Comed Action Required NRC Description of issue JFD P29 and DOC LA23 STS Table 3.3.4-1 and ITS Bases Tab!e B 3.3.4-1 CTS Table 3.3-9 l

information in CTS Table 3.3-9 and STS Table 3.3.4 1, listing " Required Number of Channels," similar to information that is retained in other ITS 3.3 sections, has been moved to ITS Bases Table B 3.3.4-1. Comment: Since this information/ table is in the CTS and the STS, and similar information has been retained in tables in other ITS 3.3 sections, retain Table 3.3.4-1

- in the ITS.

Comed Response to issue Comed will withdraw the plant specific change of relocating the RSD table to the ITS Bases in accordance with "NRC pending" TSTF-266. Table 3.3.4-1 will be retained in ITS LCO 3.3.4. LCO and Bases JFDs 3.3-P29 will be deleted. This i change will be provided in our comprehensive ITS Section 3.3 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.3 RAl. {

NRC RAI Number NRC Issued Date RAI Status 3.3.4-02 9/11/96 Open - NRC Action Required NRC Description of Issue JFD P30 STS SR 3.3.4.2 and STS SR 3.3.4.4 The STS includes SR 3.3.4.2 and SR 3.3.4.4 to confirm the oper bility of the Remote Shutdown System, not merely its instrumentation, as P30 indicates the CTS does. The ITS does not include these SRs. Comment: Include STS SR 3.3.4.2 (Q) and STS SR 3.3.4.4 in the ITS to adequately confirm the operability of the Remote Shutdown System. j Comed Response to Issue No change. As discussed in LCO and Bases JFDs 3.3-P30, it is not Byron /Braidwood Current Licensing Basis (CLB) to include control function in CTS 3.3.3.5, only instrumentation function. Comed, therefore, continues to pursue this change based on CLB.

- = = == =:= ===-= = - - = = = - _ - - -

l NRC RAI Number NRC Issued Date RAI Status 3.3.5-01 9/11/98 Open - Comed Action Required NRC Description of issue JFD P54 ITS 3.3.5, Editorial Change The word "it" has been added to Required Action C.), "to be consistent with changes in section 3.7." Comment: The addition of"if" does not add clarity, and might add confusion. Suggest deleting the word "if" from sections 3.3.5 and 3.7, for clarity and consistency.

Comed Response to issue The Note will be revised to adopt the STS wording. This change will be provided in our comprehensive ITS Section 3.3 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.3 RAl. (See RAls 3.4. I 4-02, 3.6.2-02, 3.6.3-03, 3.7.7-04, 3.7.8-06, and 3.8.1 22.)

5

. . - . . - ... n, ,. - . . - . - .-

Response to NRC RAI For ITS S:ction 3.3 17-Sep-98

==2- = . = = = = = = - = - = = - ---

NRC RAI Number NRC Issued Date RAI Status

/9 *

, 3.3.6-01 9/11/98 Open-NRC Action Required l b NRC Description of Issue l

JFD C4 and DOC L18 STS 3.3.6 Applicability ITS Table 3.3.6-1 In the STS the applicability is explicitly stated in the Applicability section of the TS, while in the ITS the applicability is referred to on Table 3.3.61. Comment: The ITS applicability is incorrect on Table 3.3.6-1, in that it does not have footnotes to include the conditions "During CORE ALTERATIONS," and "During movement ofirradiated fuel assemblies within containment." Correct the applicability on ITS Table 3.3.6-1.

Comed Response to Issue No change. ITS Table 3.3.6-1 Functions I,2, and 5 refer to LCO 3.3.2 for all initiation functions and requirements.

l Therefore, footnotes are not required for Functions 1,2, and 5.

The Applicability for Function 3, Automatic Actuation Logic and Actuation Relays, is MODES 1,2,3, and 4. This is consistent with CTS Table 3.3-3 Functional Unit 3.c.3 Applicability of MODES 1,2,3, and 4 on CTS Markup page 3/4 3-

16. Therefore, by maintaining Current Licensing Basis (CLB), footnotes are not required for Function 3.

As justified by CTS DOC 3.3-L18, the CTS Applicability of"All" has been changed in ITS for Function 4, Containment Radiation - High, to MODES 1,2,3, and 4, and when Item C.2 of LCO 3.9.4 is required. The Applicability for ITS LCO 3.9.4 is "During CORE ALTERATIONS, During movement ofirradiated fuel assemblies within containment." Therefore, footnotes are not required for Function 4. Comed continues to pursue this change based on CLB.

._= _ . - - = = . _ .;_ _ __ ;

NRC RAI Number NRC Issued Date RAI Status 3.3.6-02 9/11/98 Open - NRC Action Required NRC Description ofIssue JFD P34 STS 3.3.6 Condition B ITS 3.3.6 Condition B The ITS deletes the STS reference to manual functions in ITS 3.3.6 Condition B.

Comment: Why? Can't the system be manually actuated? Include if appropriate.

Comed Response to Issue No change. The Byron /Braidwood plant specific design does not contain a Containment Ventilation isolation - Manual Initiation function. Therefore, LCO JFD 3.3-P34 is correct in deleting this reference. Comed continues to pursue this  !

change based on Current Licensing Basis. (See RAI 3.3.6-03.)  !

- _ -~. -

..-.._..;7._7...- __._......_

l i

I I

I I

. - .,_ _ . . _ _ . _ . . ~ _ . -

6 i'

l

i

7.. .

._..,._;_.. . _. _._7; _ , . . . _ _ . . _ _ _ . . .

Response to NRC RAI For ITS Section 3.3 17-Sep-98

=. _

.. .._..,- = =.= =

NRC RAI Number NRC Issued Date RAI Status O

• 3.3.6-03 9/11/98 Open - NRC Action Required V '

NRC Description of issue JFD P34 STS SR 3.3.6.6 CTS Table 4.3.2 The CTS includes TADOT surveillances of Manual Initiation capabilities of Containment Ventilation Isolation in CTS Table 4.3.2. The STS includes this surveillance as SR 3.3.6.6. The ITS deletes this SR. Comment: Why? Include STS SR 3.3.5.6 in the ITS.

Comed Response to issue No change. The Byron /Braidwood plant specific design does not contain a Containment Ventilation isolation - Manual Initiation function. Therefore, LCO JFD 3.3-P34 is correct in deleting the corresponding SR, STS SR 3.3.6.6, for performing a TADOT on this function. Ilowever, the SR for performing an 18 month TADOT on Containment Ventilation Isolation from a Manual Initiation of Phase A and a Manual Initiation of Phase B is addressed by ITS SR 3.3.2.9. Comed continues to pursue this change based on Current Licensing Basis. (See RAI 3.3.6-02.)

. __,-., = .

.=-

NRC RAI Number NRC Issued Date RAI Status 3.3.6-04 9/11/98 Open - NRC Action Required NRC Description ofIssue DOC Ll2 ITS 3.3.6 CTS Table 3.3-6 DOC L12 explains that the CTS requires immediate closure of containment purge valves whenever a radiation monitoring V channel is inoperable, while the ITS allows 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to place the valves in the closed position. Comment: It appears to this reviewer that the ITS (and STS) allow 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to close the containment purge valves, not 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Explain how 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is allowed. Correct DOC L12 if appropriate.

Comed Response to Issue One radiation monitoring channel inputs into train 'A' of Containment Venti'ation isolation Instrumentation, while the other channel inputs into train 'B' of Containment Ventilation isolation Instrumentation. With one radiation monitoring channel froperable, one of two CIVs is affected per penetration. With the unit in MODE 1,2,3, or 4, ITS LCO 3.3.6 Condition A for one radiation monitoring channel inoperable allows 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore the affected channel to OPERABLE status. If the Required Action and associated Completion Time of Condition A is not met, Condition B requires immediately entering the applicable Conditions and Required Actions of LCO 3.6.1 for containment purge valves made inoperable by Containment Ventilation isolation Instrumentation. ITS LCO 3.6.3 Condition A, for one inoperable CIV, requires that the alTected penetration flow path be isolated within 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Thus a total of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> would be allowed to place the valves (one CIV per penetration) in the closed position whenever one radiation monitoring channel is inoperable.

O 7

Response to NRC RAI For ITS Section 3.3 17-Sep.98 NRC RAI Number NRC Issued Date RAI Status O *

, 3.3.7-01 9/11/98 Open - NRC Action Required NRC Description of Issue JFD C4 .

STS 3.3.7 Applicability 1 ITS Table 3.3.7-1 l In the STS the applicability is explicitly stated in the Applicability section of the TS, while in the ITS the applicability is referred to on Table 3.3.7-1. Comment: The ITS applicability is incorrect on Table 3.3.7-1, in that it does not have a footnote to include the condition During CORE ALTERATIONS" on ITS Table 3.3.7-1.

Comed Response to issue No change. ITS Table 3.3.7-1 Applicability for Function 1, Control Room Radiation - Gaseous, is MODES 1,2,3,4,5, and 6, and during movement ofirradiated fuel assemblies. The ITS definition for CORE ALTERATIONS states in part, " CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with l the vessel head removed and fuel in the vessel." Since the definition of MODE 6 is one or more reactor head closure bolts <

less than fully tensioned (and fuel in the vessel), CORE ALTERATIONS is encompassed in the MODE 6 Applicability. l Therefore, the footnote is not required for Function 1. '

Function 2 refers to LCO 3.3.2 for all initiation functions and requirements. Therefore, the footnote is not required for Function 2. Comed continues to pursue this change. (See RAI 3.3.6-01.)

_= -._ - . - - _, ~ ; _ - _ _ , _ _ - _ - . _

NRC RAI Number NRC Issued Date RAI Status 3.3.7-02 9/11/98 Open-NRC Action Required NRC Description of Issue

, JFD P38

\,

STS SR 3.3.7.3, STS SR 3.3.7.4, STS SR 3.3.7.5, and , STS SR 3.3.7.6 STS SR 3.3.7.3, STS SR 3.3.7.4, STS SR 3.3.7.5, and STS SR 3.3.7.6 have not been included in the ITS based on their absence in the CTS (to reflect plant specific functions ...).

Comment: Explain why the deleted STS surveillances do not confirm the operability of the VC Filtration System Actuation Instrumentation. Include surveillances as appropriate.

Comed Response to issue No change. STS was revised to delete the SRs based on Current Licensing Basis (CLB). Comed agrees that the deleted SRs provide additional verification ofoperability of the VC Filtration System Actuation Instrumentation. However, CTS provides adequate operability verification for the same actuation instrumentation. In addition, ITS SRs 3.3.2.4,3.3.2.5, 3.3.2.7, and 3.7.10.3 provide the same operability verification as STS SRs 3.3.7.3,3.3.7.4,3.3.7.5, and 3.3.7.6. Comed continues to pursue this change based on CLB. (See RAI 3.3.8-02.)

O 8

. :::::: -  ; ~ - ---

_  : 2:_:2L;_'. M r. - ~' '

L : -'

Response to NRC RAI For ITS Section 3.3 17-Sep-98 l ^NRC RAI Number' ~. -NRC _ . .issued

_ . _ -Date __ . . _ . .__ _- _ . -' RAI Staius

, 33.8-01 9/11/98 Open-NRC Action Required NRC Description ofIssue

! JFD P40 ITS 3.3.8 Required Action B.1 ITS 3.3.8 Required Action B.I states to " Place in emergency mode one FilB Ventilation System Train capable of being powered by an OPERABLE emergency power source."

Comment: Explain why the phrase " capable of being powered by an OPERABLE emergency power source" is necessary for I this required action. The status of support systems is not generally stipulated in action statements.

Comed Response to issue I l

No change. The requirement to have the FHB ventilation capable of being powered by an OPERABLE emergency power source is a CTS requirement. The rationale behind this requiremen; is that the FHB ventilation is credited for mitigating a fuel handling accident in the FilB. It is recognized that this could occur independent of unit operation, and could potentially l occur when the normal emergency power source for the affected bus is out of service for overhaul. This additional l requirement allows utilization of the unit crosstie feature to align the afTected bus to the opposite unit's diesel generator, thus providing an alternate source of AC power. Comed continues to pursue this change.

NRC RAI Number NRC issued Date RAI Status 3 3.8-02 9/11/98 Open - NRC Action Required NRC Description of issue JFD p40 STS 33.8 SR 33.83 and STS 33.8 SR 33.8.4 l

f STS 33.8 SR 33.83 and STS 33.8 SR 3.3.8.4 have not been included in the ITS based on their absence in the CTS (to reflect plant specific functions ...).

Comment: Explain why the deleted STS surveillances do not confirm the operability of the FBACS Actuation l

Instrumentation. Include surveillances as appropriate.

Comed Response to issue No change. STS was revised to delete the SRs based on Current Licensing Basis (CLB). Comed agrees that the deleted SRs provide additional verification of operability of the FilB Ventilation System Actuation Instrumentation. Ilowever, CTS provides adequate operability verification for the same actuation instrumentation. In addition, ITS SRs 33.2.4 and 3.7.13.4 provide the same operability verification as STS SRs 33.8.3 and 33.8.4. Comed continues to pursue this change based on CLB. (See RAI 33.7-02.)

=:

Bottom of Report O

b 9

_ _,