RS-14-096, Units 1 and 2 - License Amendment Request to Administratively Clarify Technical Specifications (TS) 3.3.1, Reactor Trip System (RTS) Instrumentation, and TS 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation

Units 1 and 2 - License Amendment Request to Administratively Clarify Technical Specifications (TS) 3.3.1, Reactor Trip System (RTS) Instrumentation, and TS 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation

ML14111A257
Person / Time
Site:	Byron, Braidwood
Issue date:	04/17/2014
From:	Gullott D Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-14-096
Download: ML14111A257 (44)

Text

Exelon Generation RS-14-096 10 CFR 50.90 April17, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

License Amendment Request to Administratively Clarify Technical Specifications (TS) 3.3.1, "Reactor Trip System (RTS) Instrumentation," and TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation"

References:

1) Letter from J. L. Hansen (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "License Amendment Request To Revise Technical Specifications (TS) 3.3.1, 'Reactor Trip System (RTS) Instrumentation,' and TS 3.3.2, 'Engineered Safety Feature Actuation System (ESFAS) Instrumentation,'

To Reflect Installation of Bypass Test Capability," dated March 14, 2011

2) Letter from D. M. Gullatt (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications (TS) 3.3.1, 'Reactor Trip System (RTS) Instrumentation,' and TS 3.3.2,

'Engineered Safety Feature Actuation System (ESFAS) Instrumentation,' to Reflect Installation of Bypass Test Capability, dated September 2, 2011

3) Letter from D. M. Gullatt (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Additional Information Supporting License Amendment Request to Revise Technical Specifications (TS) 3.3.1, 'Reactor Trip System (RTS) Instrumentation,' and TS 3.3.2, 'Engineered Safety Feature Actuation System (ESFAS) Instrumentation,' to Reflect Installation of Bypass Test Capability," dated November 18, 2011

4) Letter from B. L. Mozafari (U.S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "Braidwood Station, Units 1 and 2 and Byron Station, Unit Nos. 1 and 2 - Issuance of Amendments Re:

Revision of Technical Specifications (TS) 3.3.1, 'Reactor Trip System Instrumentation,' and TS 3.3.2, 'Engineered Safety Feature Actuation System Instrumentation,' (TAC Nos. ME5836, ME5837, ME5838, and ME5839)," dated March 30, 2012

April17,2014 U.S. Nuclear Regulatory Commission Page 3 Attachments 4 and 5 include the marked-up TS Bases pages with the proposed change indicated for the Braidwood Station and the Byron Station, respectively. The TS Bases pages are provided for information only and do not require NRC approval.

The proposed amendment has been reviewed by the Braidwood Station and Byron Station Plant Operations Review Committees and approved by their respective Nuclear Safety Review Boards in accordance with the requirements of the EGC Quality Assurance Program.

EGC requests approval of the proposed license amendment by April 17, 2015. Once approved, the amendments will be implemented within 60 days.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

EGC is notifying the State of Illinois of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State of Illinois official.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Ms. Dwi Murray at (630) 657-3695.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 17th day of April2014.

Respectfully, David M. Gullett Manager - Licensing Exelon Generation Company, LLC Attachments:

1. Evaluation of Proposed Change

2. Markup of Technical Specifications Pages for Braidwood Station, Units 1 and 2

3. Markup of Technical Specifications Pages for Byron Station, Units 1 and 2

4. Markup of Technical Specifications Bases Pages for Braidwood Station, Units 1 and 2

5. Markup of Technical Specifications Bases Pages for Byron Station, Units 1 and 2 cc:

NRC Regional Administrator, Region Ill NRC Senior Resident Inspector, Braidwood Station NRC Senior Resident Inspector, Byron Station NRC Project Manager, NRR - Braidwood and Byron Stations Illinois Emergency Management Agency - Division of Nuclear Safety

April17,2014 U. S. Nuclear Regulatory Commission Page2

5) Letter from M. Mahoney (U. S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "Braidwood Station, Units 1 and 2 and Byron Station, Unit Nos. 1 and 2 - Correction of Typographical Error Re: Amendments Related to the Revision of Technical Specifications (TS) 3.3.1, 'Reactor Trip System Instrumentation,' and TS 3.3.2, 'Engineered Safety Feature Actuation System Instrumentation,' (TAC Nos. ME5836, ME5837, ME5838, and ME5839)," dated April9, 2012 In Reference 1, Exelon Generation Company, LLC, (EGC) requested a license amendment to revise Technical Specifications (TS) 3.3.1, "Reactor Trip System (RTS) Instrumentation," and TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," for Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, to reflect the planned installation of the bypass test capability. EGC supplemented Reference 1 by letters dated September 2, 2011 (Reference 2) and November 18, 2011 (Reference 3).

In Reference 4, the NRC approved amendments for EGC to revise Required Action Notes in the Braidwood and Byron TS 3.3.1 and TS 3.3.2 to allow certain Functions in the RTS and ESFAS instrumentation to be tested in bypass following installation of the bypass test instrumentation modification. The amendments were supported by Westinghouse Electric Company LLC (Westinghouse) report WCAP-17349-P, Revision 1, "Bypass Test Instrumentation for Byron and Braidwood, Units 1 and 2," dated February 2011 (Proprietary). The NRC supplemented Reference 4 with a letter dated April 9, 2012 (Reference 5).

In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit or early site permit," EGC requests amendments to Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2, and Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2. This amendment request proposes to revise previously approved specific Required Action Notes-in the Braidwood and Byron TS 3.3.1 and TS 3.3.2 since they are no longer applicable following installation and implementation of the bypass test instrumentation modifications at the four Braidwood and Byron units. The proposed change reflects the specific Functions in TS 3.3.1 and TS 3.3.2 that have bypass test capability installed and the specific Functions that do not have bypass test capability installed.

The proposed change is needed to support the regulatory commitment made by EGC in a letter dated September 2, 2011 (Reference 2) to submit a follow-up license amendment request within one year following completion of installation and implementation of the bypass test instrumentation modifications. Installation and implementation of the bypass test instrumentation modification was completed during the Braidwood Unit 1 spring 2012 refueling outage (A1R16),

the Braidwood Unit 2 fall2012 refueling outage (A2R16), the Byron Unit 1 fall2012 refueling outage (B1R18), and the Byron Unit 2 spring 2013 refueling outage (B2R17) when the final modification was completed on April24, 2013.

The attached request is subdivided as follows:

- provides an evaluation of the proposed change.

Attachments 2 and 3 include the marked-up TS pages with the proposed change indicated for the Braidwood Station and the Byron Station, respectively.

ATTACHMENT 1 Evaluation of Proposed Change

Subject:

License Amendment Request to Administratively Clarify Technical Specifications (TS) 3.3.1, "Reactor Trip System {RTS) Instrumentation," and TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULA TORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedents 4.3 No Significant Hazards Consideration 4.4 Conclusion

6.0 REFERENCES

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ATTACHMENT 1 Evaluation of Proposed Change 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2, and Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2.

By letter dated March 30,2012, the NRC approved amendments for Exelon Generation Company, LLC, (EGC) to revise certain Required Action Notes in the Braidwood and Byron Technical Specifications (TS) 3.3.1, "Reactor Trip System (RTS) Instrumentation," and TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation." The approved amendments allowed certain Functions in the RTS and ESFAS instrumentation to be tested in bypass following installation of the bypass test instrumentation modification (Reference 1 ). The amendments were supported by Westinghouse Electric Company LLC (Westinghouse) report WCAP-17349-P, Revision 1, "Bypass Test Instrumentation for Byron and Braidwood, Units 1 and 2," dated February 2011 (Proprietary) (Reference 2). The NRC supplemented Reference 1 with a correction letter dated April 9, 2012 (Reference 3).

Due to the staggered implementation timeframe of the bypass test instrumentation modification across the four Braidwood and Byron units, the currently approved TS pages continue to contain the specific Required Action Notes to address Functions with installed bypass test capability and Functions without installed bypass test capability.

In a September 2, 2011 (Reference 5) letter, EGC made a regulatory commitment to submit a follow-up license amendment request within one year following completion of installation and implementation of the bypass test instrumentation modifications. Installation and implementation of the bypass test instrumentation modification was completed during the Braidwood Unit 1 spring 2012 refueling outage (A1R16), the Braidwood Unit 2 fall2012 refueling outage {A2R16), the Byron Unit 1 fall2012 refueling outage (B1R18), and the Byron Unit 2 spring 2013 refueling outage (B2R17) when the final modification was completed on April 24, 2013.

Therefore, EGC proposes to revise previously approved specific Required Action Notes in TS 3.3.1 and TS 3.3.2 since they are no longer applicable following installation and implementation of the bypass test instrumentation modifications at the four Braidwood and Byron units. The proposed change will update TS 3.3.1 and TS 3.3.2 to accurately reflect approved plant design and configuration for the specific Functions that have bypass test capability installed and Functions that do not have bypass test capability installed.

Approval of this amendment application is requested by April17, 2015. Once approved, the amendments will be implemented within 60 days.

2.0 DETAILED DESCRIPTION As documented in NRC letter dated March 30, 2012 (Reference 1 ), the following Functions in the RTS and ESFAS instrumentation have been modified and approved to have installed bypass capability and permit testing in bypass:

TS Section 3.3.1 Function 2 Power Range Neutron Flux 2 of9

Function 3 Function 6 Function 7 Function 8 Function 9 Function 10 Function 14 TS Section 3.3.2 ATTACHMENT 1 Evaluation of Proposed Change Power Range Neutron Flux - High Positive Rate Overtemperature Ll T Overpower Ll T Pressurizer Pressure Pressurizer Water Level - High Reactor Coolant Flow-Low Steam Generator Water Level - Low Low Function 1.c Safety Injection - Containment Pressure - High 1 Function 1.d Safety Injection - Pressurizer Pressure - Low Function 1.e Safety Injection-Steam Line Pressure-Low Function 4.c Steam Line Isolation-Containment Pressure-High 2 Function 4.d Steam Line Isolation - Steam Line Pressure Function 5.b Turbine Trip and Feedwater Isolation -Steam Generator Water Level-High High (P-14)

Function 6.b Auxiliary Feedwater-Steam Generator Water Level -Low Low Function 7.b Switch over to Containment Sump-Refueling Water Storage Tank Levei-LowLow The listed RTS and ESFAS instrumentation Functions are identified in TS Table 3.3.1-1, "Reactor Trip System Instrumentation," and Table 3.3.2-1, "Engineered Safety Feature Actuation System Instrumentation." Required Actions Notes in TS 3.3.1, Conditions D, E, and K, and in TS 3.3.2, Conditions D and K, were revised to allow the surveillance testing (and setpoint adjustment) to be done in bypass for functions with installed bypass capability.

Following completion of installation and implementation of the bypass test instrumentation modifications, the proposed change will revise the TS and corresponding Bases as part of a separate, clean-up license amendment. Specifically, the proposed change will revise TS 3.3.1, Conditions D and E, TS 3.3.2, Conditions D and K, and the corresponding Bases pages to reflect the applicable functions that have bypass test capability installed. Additionally, the proposed change will revise TS 3.3.1, Condition K, and the corresponding Bases pages to reflect the specific functions that have bypass test capability installed and the specific functions that do not have bypass test capability installed.

The TS 3.3.1, Condition D, Required Action Notes would be changed to have one Note. The new Note would state, "One channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing and setpoint adjustment." The Note related to functions with no installed bypass test capability would be removed as it is no longer applicable since the functions contained within this TS Condition have bypass test capability installed.

The TS 3.3.1, Condition E, Required Action Notes would be changed to have one Note. The new Note would state, "One channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing." The Note related to functions with no installed bypass test capability would be removed as it is no longer applicable since the functions contained within this TS Condition have bypass test capability installed.

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ATTACHMENT 1 Evaluation of Proposed Change The TS 3.3.1, Condition K, Required Action Notes would be changed to reflect the specific functions that have bypass test capability installed and the specific functions that do not have bypass test capability installed. Note 1 would be change to state, "For Functions with installed bypass test capability (Functions 8a, 9, 10), one channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing." Note 2 would be changed to state, "For Functions with no installed bypass test capability (Functions 12 and 13), the inoperable channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing of other channels."

The TS 3.3.2, Condition D, Required Action Notes would be changed to have one Note. The new Note would state, "One channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing." The Note related to functions with no installed bypass test capability would be removed as it is no longer applicable since the functions contained within this TS Condition have bypass test capability installed.

The TS 3.3.2, Condition K, Required Action Notes would also be changed to have one Note.

The new Note would state, "One channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing." The Note related to functions with no installed bypass test capability would be removed as it is no longer applicable since the functions contained within this TS Condition have bypass test capability installed.

The marked-up TS pages provided in Attachments 2 and 3 indicate the proposed change to the Braidwood Station and Byron Station TS, respectively.

Attachments 4 and 5 contain the proposed mark-ups of the affected TS Bases pages for Braidwood and Byron Station, respectively, for information only. Changes to TS Bases 3.3.1, Conditions D and E, and TS Bases 3.3.2, Conditions D and K are required to reflect the applicable functions that have bypass test capability installed. Changes to TS Bases 3.3.1, Condition K are required to reflect the specific functions that have bypass test capability installed and the specific functions that do not have bypass test capability installed. These changes will be made in accordance with the Braidwood and Byron TS Bases Control Program.

3.0 TECHNICAL EVALUATION

Following completion of installation and implementation of the bypass test instrumentation modifications for the Braidwood and Byron units, the existing Note 2 is no longer applicable and therefore obsolete to TS 3.3.1 Conditions D and E and to TS 3.3.2 Conditions D and K as all applicable functions have bypass test capability installed.

ForTS 3.3.1 Condition K, the following functions in the RTS instrumentation have been modified and approved to have installed bypass capability and permit testing in bypass:

Function 8.a Pressurizer Pressure-Low Function 9 Pressurizer Water Level - High Function 10 Reactor Coolant Flow - Low Function 12 {Undervoltage RCPs) and Function 13 (Underfrequency RCPs) were not modified to have installed bypass capability.

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ATTACHMENT 1 Evaluation of Proposed Change The proposed change is administrative in nature because it updates the TS to accurately reflect approved plant design and configuration. The proposed change to revise previously approved specific Required Action Notes in TS 3.3.1 and TS 3.3.2 does not affect how plant equipment is operated or maintained. There are no changes to the physical plant or described analytical methods and there are no impacts on the Updated Final Safety Analysis Report (UFSAR) accident analysis. Reference 2 contains the technical basis and methodology associated with the bypass test capability.

The proposed change is needed to support the regulatory commitment made by EGC in a letter dated September 2, 2011 (Reference 5) to submit a follow-up license amendment request within one year following completion of installation and implementation of the bypass test instrumentation modifications. The final modification was completed during the Byron Unit 2 spring 2013 refueling outage (B2R17) on April24, 2013.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36(c){1), "Safety limits, limiting safety system settings, and limiting control settings," paragraph (ii)(A) defines the limiting safety system settings for nuclear reactors as settings for automatic protective devices related to those variables having significant safety functions. Where a limiting safety system setting is specified for a variable on which a safety limit has been placed, the setting must be so chosen that automatic protective action will correct the abnormal situation before a safety limit is exceeded.

Furthermore, Criterion 3 of 10 CFR 50.36(c)(2}(ii) requires that a TS Limiting Condition for Operation must be established for a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

The proposed change to revise previously approved specific Required Action Notes in the Braidwood and Byron TS 3.3.1 and TS 3.3.2 are administrative in nature and will update the TS to accurately reflect approved plant design and configuration. The proposed change has no impact on current safety limits, limiting safety system settings, limiting control settings, limiting conditions for operation, surveillance requirements, design features, and administrative controls as required by TS. Therefore, the proposed change continues to meet applicable requirements and criteria of 10 CFR 50.36, "Technical Specifications."

4.2 Precedents EGC is not aware of any precedents for license amendment requests to revise previously approved specific Required Action Notes in TS 3.3.1 and TS 3.3.2 to allow certain Functions in the RTS and ESFAS instrumentation to be tested in bypass following installation and implementation of the bypass test instrumentation modification.

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ATTACHMENT 1 Evaluation of Proposed Change 4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit or early site permit," Exelon Generation Company, LLC, (EGC) requests amendments to Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2, and Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2. This amendment request proposes to administratively revise previously approved specific Required Actions Notes from the Braidwood and Byron TS 3.3.1, "Reactor Trip System {RTS) Instrumentation," and TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation." These specific Required Actions Notes are no longer applicable since the related modifications have been installed and implemented and the proposed change will reflect approved plant design and configuration.

The proposed change is needed to support the regulatory commitment made by EGC in a letter dated September 2, 2011 (Reference 5) to submit a follow-up license amendment request within one year following completion of installation and implementation of the bypass test instrumentation modifications at the four Braidwood and Byron units. The final modification was completed during the Byron Unit 2 spring 2013 refueling outage (B2R17) on April24, 2013.

According to 10 CFR 50.92, "Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

(1)

Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2)

Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3)

Involve a significant reduction in a margin of safety.

EGC has evaluated the proposed change for Braidwood Station and Byron Station, using the criteria in 10 CFR 50.92, and has determined that the proposed change does not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.

Criteria

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change is administrative in nature as it revises previously approved specific TS Required Actions Notes that are no longer applicable following plant modification installation and implementation to reflect the applicable RTS and ESFAS Functions with installed bypass test capability.

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ATTACHMENT 1 Evaluation of Proposed Change The proposed change does not impact any accident initiators, analyzed events, or assumed mitigation of accident or transient events modeled in the safety analyses. The proposed change does not alter the design assumptions, conditions, or configuration of the facility, nor does it affect the structural and functional integrity of the RTS and ESFAS. The proposed change does not alter or prevent the ability of any structures, systems, and components from performing their intended design function to mitigate the consequences of an initiating event within the applicable acceptance criteria.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change to revise previously approved specific TS Required Actions Notes that are no longer applicable to specific RTS and ESFAS Functions with installed bypass test capability is administrative in nature. The proposed change does not result in a change to any design function or the manner in which the RTS and ESFAS operates to provide plant protection. The RTS and ESFAS will continue to have the same setpoints after the proposed change is implemented. In addition, this change does not install or modify any plant equipment. Therefore, no new failure modes are being created nor does the change result in the creation of any changes to the existing accident scenarios or do they create any new or different accident scenarios. The types of accidents defined in the UFSAR continue to represent the credible spectrum of events to be analyzed which determine safe plant operation.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

No safety analyses are changed or modified as a result of the proposed change to revise previously approved specific TS Required Actions Notes that are no longer applicable toRTS and ESFAS Functions with installed bypass test capability. The proposed change does not alter the manner in which the safety limits, limiting safety system settings, or limiting conditions for operation are determined. Margins associated with the current applicable safety analyses acceptance criteria are unaffected. The current safety analyses remain bounding since their conclusions are not affected by this change and the plant will continue to operate in a manner consistent with the safety analyses. The safety systems credited in the safety analyses will continue to be available to perform their mitigation functions.

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ATTACHMENT 1 Evaluation of Proposed Change Therefore, the proposed change does not result in a significant reduction in the margin of safety.

Based on the above evaluation, EGC concludes that the proposed amendments do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (c), and, accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by the operation of Byron and Braidwood Units 1 and 2 in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

EGC has evaluated the proposed amendment for environmental considerations. The review has resulted in the determination that the proposed amendment would not change the requirements with respect to installation or use of a facility component located within the restricted area, as defined in 1 0 CFR 20, or change an inspection or Surveillance Requirement.

Additionally, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22, paragraph {b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

6.0 REFERENCES

1)

Letter from B. L. Mozafari {U.S. Nuclear Regulatory Commission) toM. J. Pacific (Exelon Generation Company, LLC), "Braidwood Station, Units 1 and 2 and Byron Station, Unit Nos. 1 and 2 -Issuance of Amendments Re: Revision of Technical Specifications (TS) 3.3.1, 'Reactor Trip System Instrumentation,' and TS 3.3.2,

'Engineered Safety Feature Actuation System Instrumentation," (TAC Nos.

ME5836, ME5837, ME5838, and ME3839)," dated March 30,2012

2)

Westinghouse Electric Company LLC, WCAP-17349-P, Revision 1, "Bypass Test Instrumentation for Byron and Braidwood Units 1 and 2," February 2011 (Proprietary) 8of9

ATTACHMENT 1 Evaluation of Proposed Change

3)

Letter from M. Mahoney (U. S. Nuclear Regulatory Commission) toM. J. Pacilio (Exelon Generation Company, LLC), "Braidwood Station, Units 1 and 2 and Byron Station, Unit Nos. 1 and 2 - Correction of Typographical Error Re: Amendments Related to the Revision of Technical Specifications (TS) 3.3.1, 'Reactor Trip System Instrumentation,' and TS 3.3.2, 'Engineered Safety Feature Actuation System Instrumentation," (TAG Nos. ME5836, ME5837, ME5838, and ME5839)," dated Apri19, 2012

4)

Letter from J. L. Hansen (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request to Revise Technical Specifications (TS) 3.3.1, 'Reactor Trip System (RTS) Instrumentation,' and TS 3.3.2, 'Engineered Safety Feature Actuation System (ESFAS) Instrumentation,' to Reflect Installation of Bypass Test Capability," dated March 14, 2011 (Proprietary)

5)

Letter from D. M. Gullatt (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications (TS) 3.3.1,

'Reactor Trip System (RTS) Instrumentation,' and TS 3.3.2, 'Engineered Safety Feature Actuation System (ESFAS) Instrumentation,' to Reflect Installation of Bypass Test Capability," dated September 2, 2011 9 of9

ATTACHMENT 2 Markup of Technical Specifications Pages for Braidwood Station, Units 1 and 2 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 AFFECTED TECHNICAL SPECIFICATIONS PAGES 3.3.1-3 3.3.1 -4 3.3.1-6 3.3.2-3 3.3.2-7

ACTIONS (continued)

CONDITION D.

One Power Range Neutron Flux-High channel inoperable.

One channel may be f.-1 bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing and setpoint adjustment.

BRAIDWOOD UNITS 1 & 2 REQUIRED ACTION

---

NOTE~------------

+:-

FeF Ft~net~ ens ~'~ tfl

~Asta~~ea ~~ass test ea~=Jal3~1~ey, one eflaAnei may ee ~passed fer up to

!2 AOUPS fer SHPYC~~~aRCC 11 testing aAd set13oint adjt~stmeRt.

b FeF FttReM eAs *,iHA no insta~ied ~pass test capaei~iey, tfle

~~e~;~~~~de~:~n~; ~~

!2 AOtiPS foP SUPYei~iaRCC test~Ag aRd setpeiAt adjustmeAt of otf:ler ef:lanAels.

D.1 Place channel in trip.

OR D.2 Be in MODE 3.

3.3.1-3 RTS Instrumentation 3.3.1 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 78 hours (contlnued)

Amendment +/-6 ACTIONS (continued)

CONDITION E.

One channel inoperable.

One channel may be bypassed for up to -

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing.

BRAIDWOOD - UNITS 1 & 2 REQUIRED ACTION

---

NOTE£------------

-+/--. FeP Fl:lAet~ eAs

• ~~~~ t~

~A stan eEl Byf3ass test eaj3al3~i~ty. 8Ae e~aAAe~

ma¥ se Byf3asseEI :fep 1:113 te t

12 h8Uf'S :fep SUf'Ye~llaACe testiR§.

b Fef' FbiAeM BAS

'I~~ th R8

~As:talleEI B¥f3ass test eaf3al3il~ty, the

~~e~;~~~~8e~~~A~~ :~,

12 heurs :fer sl:lrve~~laAee test~Ag e:f et~er ehaAAels.

E.1 Place channel in trip.

OR E.2 Be in MODE 3.

3.3.1-4 RTS Instrumentation 3.3.1 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 78 hours (continued)

Amendment -+/-69

ACTIONS (continued)

CONDITION K.

One channel inoperable.

(Functions 8a, 9, 10)

(Functions 12 and 13)

L.

One Turbine Trip channel inoperable.

BRAIDWOOD - UNITS 1 & 2 REQUIRED ACTION

---

--NOTES------------

1.

For Functions with installed bypass test capabili

, one channel may be assed for up to 12 rs for surveillance t

ing.

K.1 OR Place channel in trip.

RTS Instrumentation 3.3.1 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> K. 2 Reduce THERMAL POWER 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> to< P-7.

---

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

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing of other channels.

L.1 OR Place channel in trip.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> L. 2 Reduce THERMAL POWER 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> to < P-8.

(continued) 3.3.1 6

Amendment -+/-W

ACTIONS (continued)

CONDITION D.

One channel inoperable.

One channel may be ~

bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing.

BRAIDWOOD - UNITS 1 & 2 D.l

/

OR D.2.1 AND D.2.2 ESFAS Instrumentation 3.3.2 REQUIRED ACTION COMPLETION TIME

---

NOTE&----- --

1. Fer Fcn1e:M eAs H~tA

~ As:tan eEl Byf3ass

tes:t eaf3al3~~~t;*.

eAe eFiaAAe~ ma;Y 13e l:lyf3asseEI ter Hf3 :te 12 heHrs ter sHr~o*e~ ~ ~ aAee

testiAg.

2. Fer FHAeM 8A5

~~~ :Eh 198 ~AStaiieEI 6yf3ass :tes:t eaf3aB~i~t-y. :tl9e

~Aef3eraeie ehaAAe~

ma;Y se B;Y!JasseEI ter Hf3 :te 12 A8HrS fer SHP~o*e~ i i aAee

tes:t~Ag ef e:tl9er el9aAAels.

Place channel in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> trip.

Be in MODE 3.

78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> Be in MODE 4.

84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> (cont1nued) 3.3.2 - 3 Amendment -+/

ESFAS Instrumentation 3.3.2 ACTIONS (continued)

CONDITION K.

One channel inoperable.

K.l REQUIRED ACTION

---

NOTE~------

h For Functi ens Hith installed b;ypass test capability, one channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing.

One channel may be '---'~

bypassed for up to

-b-For Functi ens

• ,Jith no installed b:Ypass test capability, the inoperable channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing of other channels.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing.

BRAIDWOOD - UNITS 1 & 2 OR Place channel in trip.

K.2.1 Be in MODE 3.

AND K.2.2 Be in MODE 5.

3.3.2 - 7 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 78 hours 108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br /> (cont1nued)

Amendment +69-

ATTACHMENT 3 Markup of Technical Specifications Pages for Byron Station, Units 1 and 2 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 AFFECTED TECHNICAL SPECIFICATIONS PAGES 3.3.1-3 3.3.1-4 3.3.1-5 3.3.2-3 3.3.2-7

ACTIONS (continued)

CONDITION D.

One Power Range Neutron Flux-High channel inoperable.

One channel may be f--.1 bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing and setpoint adjustment.

BYRON - UNITS 1 & 2 REQUIRED ACTION

---

NOTE~------------

h FoP FI:IACt~ OAS

'n'~ th

~As:Eaiiee 8y~ass :Ees:E ea~aM 1 4 ey, oRe ehaAAei ma~ ee ~~asses ~oF 1:1~ to

+/-2 AOI:IFS ~oF s~:~Fve~iiaAee lJ1 testiAg ana SCt~Oint aeji:IStmeAt.

b FoP F~:~Aeti ens ~.;itl9 Ao iAs:Eaiiea 9J*~ass test ea~aeiiiey, :Efle

~=o~;:~~~8e~;~A~~ :~

+/-2 flel::lFS ~oF Sl::lF~*ei i 1 aAee tCStiAg aAa Set~OiAt aajUStffient 0~ Other channels.

D.l Place channe 1 in trip.

OR D.2 Be in MODE 3.

3.3.1-3 RTS Instrumentation 3.3.1 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 78 hours (contlnued)

Amendment -l-ffl.

ACTIONS (continued)

CONDITION E.

One channel inoperable.

One channel may be _/

bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing.

F.

One Intermediate Range Neutron Flux channel inoperable.

G.

Two Intermediate Range Neutron Flux channels inoperable.

H.

One Source Range Neutron Flux channel inoperable.

BYRON - UNITS 1 & 2 REQUIRED ACTION

---

NOTE£---- -- -- -

.+/---;-

FaF FI:IAeM eAs

'i~~ til

~Asta~~ea ey~ass test ea~as~1~t:Y. eAe ellaAAe~

ma;t 13e B:Y~assea :Fer 1::1~ te 12 !leurs :Fer surve~llaAce l11 testing.

b Fer Ft:meti eAs ~~~ tf:l Ae

~Asta~~ea 13;'~ass test ea~aM l i ey, tf:le

~~e~;~~!~ae~:~A~~ :~

12 l1e1::1rs :FeP s~:~rveillaAee testiAg e:F ether cf:laAnels.

E.l Place channel in trip.

OR E.2 Be in MODE 3.

F.l Reduce THERMAL POWER to < P-6.

OR F.2 Increase THERMAL POWER to > P-10.

G.l Suspend operations involving positive reactivity additions.

AND G.2 Reduce THERMAL POWER to < P-6.

H.l Suspend operations involving positive reactivity additions.

3.3.1-4 RTS Instrumentation 3.3.1 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 78 hours 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 2 hours Imnediately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> I!TlTlediately (continued)

Amendment -+/

ACTIONS (continued)

CONDITION I.

Two Source Range Neutron Flux channels inoperable.

J. One Source Range Neutron Flux channel inoperable.

K.

One channel inoperable.

(Functions 8a, 9, 10)

(Functions 12 and 13)

BYRON - UNITS 1 & 2 1.1 J.l REQUIRED ACTION Open Reactor Trip Breakers (RTBs).

Restore channel to OPERABLE status.

J.2.1 Initiate action to fully insert all rods.

AND RTS Instrumentation 3.3.1 COMPLETION TIME Irrrnediately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 48 hours J. 2. 2 Place the Rod Contra l 49 hours5.671296e-4 days <br />0.0136 hours <br />8.101852e-5 weeks <br />1.86445e-5 months <br /> System in a condition incapable of rod withdrawal.

---

-NOTES--

1.

For Functions with installed bypass test capabilit, one channel may be assed for up to 12 h rs for surveillance t

ing.

K.1 OR For Functions with no installed bypass test capabilit, the inoper channel may be assed for up to hours for surveillance testing of other channels.

Place channel in trip.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> K. 2 Reduce THERMAL POWER 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> to< P-7.

3.3.1 5

(continued)

Amendment +76-

ACTIONS (continued)

CONDITION D.

One channel inoperable.

D.1 REQUIRED ACTION ESFAS Instrumentation 3.3.2 COMPLETION TIME

-- -- --NOTE£--- --- -

~ For Functions

'ivi th i nsta11 ed bypass test capability, one channel rnay be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for One channel may be !--L----'*

surveillance testing.

bypassed for up to

-b-For Functions with no installed bypass test capability, the inoperable channel rnay be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing of other channels.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing.

BYRON - UNITS 1 & 2 OR Place channel in trip.

D.2.1 Be in MODE 3.

AND D.2.2 Be in MODE 4.

3.3.2 - 3 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 78 hours 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> (cont1nued)

Amendment m

ESFAS Instrumentation 3.3.2 ACTIONS (continued)

CONDITION K.

One channel inoperable.

K.1 REQUIRED ACTION

---

NOTE£--- ----

~ For Functions

• .with installed bypass test capability, one channel may be bypassed for up One channel may be _l_.----?"

bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for b

to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing.

For Functions surveillance testing.

BYRON - UNITS 1 & 2 OR with no installed bypass test capability, the inoperable channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing of other channels.

Place channel in trip.

K. 2.1 Be in MODE 3.

AND K.2.2 Be in MODE 5.

3.3.2-7 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 78 hours 108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br /> (contlnued)

Amendment m

ATTACHMENT 4 Markup of Technical Specifications Bases Pages for Braidwood Station, Units 1 and 2 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 AFFECTED TECHNICAL SPECIFICATIONS BASES PAGES (NOTE: TS Bases pages are provided for information only.)

B 3.3.1-42 B 3.3.1-43 B 3.3.1 -44 B 3.3.1 -47 B 3.3.1-48 B 3.3.2-43 B 3.3.2-44 B 3.3.2-49 B 3.3.2-50

BASES RTS Instrumentation B 3.3.1 ACTIONS (continued)

The Completion Time is reasonable considering that in this Condition, the remaining OPERABLE train is adequate to perform the safety function, and given the low probability of an event occurring during this interval.

A Note to the ACTIONS restricts the transition from MODE 5 with the Rod Control System not capable of rod withdrawal and all rods fully inserted, to MODE 5 with the Rod Control System capable of rod withdrawal or all rods not fully inserted for Functions 18, 19, and 20 while complying with the ACTIONS (i.e., while the LCO is not met).

LCO 3.0.4 typically allows entry into MODES or other specified conditions in the Applicability while in MODE 5, however, the restriction of this Note is necessary to assure an OPERABLE RTS function prior to commencing operation with the Rod Control System capable of rod withdrawal or all rods not fully inserted.

D.l and D.2 Condition D applies to the Power Range Neutron Flux-High Function.

The NIS power range detectors provide input to the Rod Control System and the SG Water Level Control System and, therefore, have a two-out-of-four trip logic. A known inoperable channel must be placed in the tripped condition.

This results in a partial trip condition requiring only one-out-of-three logic for actuation. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the inoperable channel in the tripped condition is justified in Reference 14.

As an alternative to the above Action, the plant must be placed in a MODE where this Function is no longer required OPERABLE.

Seventy eight hours are allowed to place the plant in MODE 3. The 78 hour9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> Completion Time includes 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for channel corrective maintenance and an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for the MODE reduction as required by Required Action D.2. This is a reasonable time, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging plant systems. If Required Actions cannot be completed within their allowed Completion Times, LCO 3.0.3 must be entered.

BRAIDWOOD - UNITS 1 & 2 B 3.3.1 42 Revision 88

BASES ACTIONS RTS Instrumentation B 3.3.1 (continued)

~

The Required Actions are modified by tW& Note57 The first Note appltes to Fun~tions that have installed bypass capabiltty. The Note allows placing one channel in bypass for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing surveillance testing, and setpoint adjustments when a setpoint reduction is required by other.Technical Specificati?ns. The second Note ?P9lies to Funct1ons that do not have 1nstali-ed bypass eaj3abiHt:Y.

This Note a11oHs placing the inoperable channel in bypass for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> v~hi 1 e performing survei 11 a nee testing or setpoint adjustments of other channels.

When surveillance testing is performed for functions ~iith installed bypass test capability under the Required Action Note, the appropriate TS Condition is entered, and the Required Action Note is applied, allowing an inoperable channel to be placed in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The Completion Time starts after the time in the Required Action Note expires, providing the equipment remains removed from service or bypassed. If the surveillance time exceeds 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the Required Action would have to be performed (e.g., place channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />.)

In addition, for channels with installed bypass test capability, if a channel is discovered inoperable, the bypass test capability could be utilized during troubleshooting prior to expiration of the appropriate TS Condition Required Action Completion Time to place the channel in trip. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference 14. th h

1 b

1

d.

e c anne may e p ace m a E.1 and E. 2 bypass condition r----~

Condition E applies to the following reactor trip Functions:

Power Range Neutron Flux-Low; Overtemperature ~T; Overpower ~T; Power Range Neutron Flux-High Positive Rate; Pressurizer Pressure-High; and SG Water Level-Low Low.

A known inoperable channel must be placed in the tripped condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Placing the channel in the tripped condition results in a partial trip condition BRAIDWOOD UNITS 1 & 2 B 3.3.1 43 Revi sian B&

BASES RTS Instrumentation B 3.3.1 ACTIONS (continued) requiring only one-out-of-three logic for actuation of the two-out-of-four trips. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the inoperable channel in the tripped condition is justified in Reference 14.

If the inoperable channel cannot be placed in the trip condition within the specified Completion Time, the unit must be placed in a MODE where these Functions are not required OPERABLE.

An additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed to place the unit in MODE 3. Six hours is a reasonable time, based on operating experience, to place the unit in MODE 3 from full power in an orderly manner and without challenging plant systems.

~

The Required Actions are modified by~ Note&T The first

~~:~ ~~~~es ¥~ F~~~!ions that have installed bypass b: ~~. The Note allows placing one channel in bf~~ss for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing surveillance testing.

When surveillance testing is performed for functions ~iith installed bypass test capability under the Required Action Note, the appropriate TS Condition is entered, and the Required Action Note is applied, allowing an inoperable channel to be placed in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The Completion Time starts after the time in the Required Action Note expires, providing the equipment remains removed from service or bypassed.

If the surveillance time exceeds 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the Required Action would have to be performed (e.g., place channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />.)

In addition, for channels with installed bypass test capability, if a channel is discovered inoperable, the bypass test capability could be utilized during troubleshooting prior to expiration of the appropriate TS Condition Required Action Completion Time to place the channel in trip. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference 14. the channel may be placed in a 1-----'"""'

F.1 and F. 2 bypass condition Condition F applies to the Intermediate Range Neutron Flux trip when THERMAL POWER is above the P-6 setpoint and below the P-10 setpoint and one channel is inoperable. Above the P-6 setpoint and below the P-10 setpoint, the NIS intermediate range detector performs the monitoring BRAIDWOOD - UNITS 1 & 2 B 3.3.1 - 44 Revision -88

BASES RTS Instrumentation B 3.3.1 ACTIONS (continued)

K.1 and K.2 Condition K applies to the following reactor trip Functions:

Pressurizer Pressure-Low; Pressurizer Water Level-High; Reactor Coolant Flow-Low; Undervoltage RCPs; and Underfrequency RCPs.

With one channel inoperable, the inoperable channel must be placed in the tripped condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Placing the channel in the tripped condition results in a partial trip condition requiring only one additional channel to initiate a reactor trip above the P-7 setpoint. These Functions do not have to be OPERABLE below the P-7 setpoint.

The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the channel in the tripped condition is justified in Reference 14.

An additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed to reduce THERMAL POWER to below P-7 if the inoperable channel cannot be restored to OPERABLE status or placed in trip within the specified Completion Time.

Allowance of this time interval takes into consideration the redundant capability provided by the remaining redundant OPERABLE channel, and the low probability of occurrence of an event during this period that may require the protection afforded by the Functions associated with Condition K.

Ba, 9, and 10 The Required Actions are dified by two Notes.

The first Note applies to Functions that have installed bypass capability. The Note allows placing one channel in by ass for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing sur e

• 12 and 13 second Note applies to Functions at do not have installed bypass capability. This Note allows placing the inoperable channel in bypass for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing surveillance testing of other channels.

When surveillance testing is performed for functions with installed bypass test capability under the Required Action Note, the appropriate TS Condition is entered, and the Required Action Note is applied, allowing an inoperable channel to be placed in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The Completion Time starts after the time in the Required Action Note expires, providing the equipment remains removed from BRAIDWOOD - UNITS 1 & 2 B 3.3.1 - 47 Revision -88

BASES RTS Instrumentation B 3.3.1 ACTIONS (continued) service or bypassed.

If the surveillance time exceeds 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the Required Action would have to be performed (e.g., place channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />.)

In addition, for channels with installed bypass test capability, if a channel is discovered inoperable, the bypass test capability could be utilized during troubleshooting prior to expiration of the appropriate TS Condition Required Action Completion Time to place the channel in trip. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference 14.

L.l and L.2 Condition L applies to Turbine Trip on Emergency Trip Header Pressure or on Turbine Throttle Valve Closure. With one channel inoperable, the inoperable channel must be placed in the trip condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

If placed in the tripped condition, this results in a partial trip condition requiring only one additional channel to initiate a reactor trip. If the channel cannot be restored to OPERABLE status or placed in the trip condition, then power must be reduced below the P-8 setpoint within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the inoperable channel in the tripped condition is justified in Reference 14.

The Required Actions have been modified by a Note that allows placing the inoperable channel in the bypassed condition for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing of the other channels. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference 14.

M.l and M.2 Condition M applies to the SI Input from ESFAS reactor trip and the RTS Automatic Trip Logic in MODES 1 and 2. These actions address the train orientation of the RTS for these Functions. With one train inoperable, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are allowed to restore the train to OPERABLE status (Required Action M.1) or the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Required Action M.1) is reasonable considering that in this Condition, the remaining OPERABLE train is adequate to perform the safety function and given the low probability of an event during this interval. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed to restore the inoperable RTS Automatic Trip Logic train to OPERABLE status is justified in Reference 14.

The Completion Time of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (Required Action M.2) is reasonable, based on operating experience, to reach MODE 3 BRAIDWOOD - UNITS 1 & 2 B 3.3.1-48 Revision 88

BASES ESFAS Instrumentation B 3.3.2 ACTIONS (continued)

The Required Actions are modified by a Note that allows one train to be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing, provided the other train is OPERABLE.

This allowance is based on the reliability analysis assumption of WCAP-10271-P-A (Ref. 7) that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the average time required to perform train surveillance.

0.1. 0.2.1. and 0.2.2 Condition 0 applies to:

Containment Pressure-High 1; Pressurizer Pressure-Low; Steam Line Pressure-Low; Containment Pressure-High 2; Steam Line Pressure-Negative Rate-High; SG Water Level-Low Low; and SG Water Level-High High (P-14).

If one channel is inoperable, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are allowed to restore the channel to OPERABLE status or to place it in the tripped condition. Generally, this Condition applies to functions that operate on two-out-of-three logic or a two-out-of-four logic. Therefore, failure of one channel places the Function in a two-out-of-two configuration. One channel must be tripped to place the Function in a one-out-of-two configuration that satisfies redundancy requirements.

The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to restore the channel to OPERABLE status or to place it in the tripped condition is justified in Reference 15.

Failure to restore the inoperable channel to OPERABLE status or place it in the tripped condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requires the unit be placed in MODE 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 4, these Functions are no longer required OPERABLE.

BRAIDWOOD - UNITS 1 & 2 B 3.3.2 - 43 Revision 70

BASES ESFAS Instrumentation B 3.3.2 ACTIONS (continued)

~

The Required Actions are modified by tW& Not~ The first

~~:~ ~~~~es ~~ F~~~~ions that have installed b;ypass b: ~~. The Note allows placing one channel in bf~~ss for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing surveillance testing.

~:~~~ ~~;:brfW~~s f~;;u~~i!o~~,~~~tP~~c~~; ~~~ei!~:!~!!f~

When survei 11 ance testing is performed for functions vi'i th installed b;ypass test capability under the Required Action Note, the appropriate TS Condition is entered, and the Required Action Note is applied, allowing an inoperable channel to be placed in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The Completion Time starts after the time in the Required Action Note expires, providing the equipment remains removed from service or bypassed.

If the surveillance time exceeds 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the Required Action would have to be performed (e.g., place channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />.)

In addition, for channels ~~ith installed bypass test capability, if a channel is discovered inoperable, the bypass test capability could be utilized during troubleshooting prior to expiration of the appropriate TS Condition Required Action Completion Time to place the channel in trip. The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for testing, is justified in Refr:-:e_re;_n-:-ce.;.......;;1_5--:-. ----::---:------::--:----.

the channel may be placed in a E.l. E. 2.1. and E. 2

• 2 bypass condition t-----~

Condition E applies to:

Containment Spray Containment Pressure-High 3; and Containment Phase B Isolation Containment Pressure High 3.

None of these signals has input to a control function.

Thus, two-out-of-three logic is necessary to meet acceptable protective requirements.

However, a two-out-of-three design would require tripping a failed channel. This is undesirable because a single failure would then cause spurious containment spray initiation. Spurious spray actuation is undesirable because of the cleanup problems presented. Therefore, these channels are designed with two-out-of-four logic so that a failed channel may be bypassed rather than tripped. Note that one channel may be bypassed and still satisfy the single failure criterion.

Furthermore, with one channel bypassed, a single BRAIDWOOD - UNITS 1 & 2 B 3.3.2 - 44 Revi sian 8&

BASES ESFAS Instrumentation B 3.3.2 ACTIONS (continued)

J.l Condition J applies to the Auxiliary Feedwater Pump Suction Transfer on Suction Pressure-Low Function.

With one train inoperable, the associated auxiliary feedwater pump must be immediately declared inoperable. This requires entry into applicable Conditions and Required Actions of LCD 3.7.5, "AF System."

K.l. K.2.1. and K.2.2 Condition K applies to the RWST Level-Low Low Coincident with Safety Injection Function.

RWST Level-Low Low Coincident with SI provides actuation of switchover to the containment sump.

Note that this Function requires the bistables to energize to perform their required action.

This Condition applies to a Function that operates on two-out-of-four logic. Therefore, failure of one channel places the Function in a two-out-of-three configuration.

One channel must be tripped to place the Function in a one-out-of-three configuration that satisfies redundancy requirements.

If the channel cannot be returned to OPERABLE status or placed in the tripped condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the unit must be brought to MODE 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 5, the unit does not have any analyzed transients or conditions that require the explicit use of the protection function noted above.

~

The Required Actions are modified by tw& Note&. The first Note appltes to Functions that have installed bypass capability. The Note allows placing one channel in bypass for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing surveillance testing. +fle

~~~~~ ~~:~b~~W~~s f~;:u~gi!o~i,:~tP~~c~~: :~~e;!;~:~!~~~

channel in bypass for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ~rhi 1 e performing survei 11 a nee testing of other channels.

BRAIDWOOD - UNITS 1 & 2 B 3.3.2-49 Revi sian 88

BASES ESFAS Instrumentation 8 3.3.2 ACTIONS (continued)

When surveillance testing is performed for functions 'n'ith installed bypass test capability under the Required Action Note, the appropriate TS Condition is entered, and the Required Action Note is applied, allowing an inoperable channel to be placed in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The Completion Time starts after the time in the Required Action Note expires, providing the equipment remains removed from service or bypassed. If the surveillance time exceeds 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the Required Action would have to be performed (e.g., place channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />.)

In addition, for channels ~,.dth installed bypass test capability, if a channel is discovered inoperable, the bypass test capability could be utilized during troubleshooting prior to expiration of the appropriate TS Condition Required Action Completion Time to" place the channel in trip. This is acceptable based on the '

results of Reference 15.

th h

1 b

1 d.

e c anne may e p ace m a 1-----..::0..

L.l. L. 2. 1 and L. 2. 2 bypass condition Condition L applies to the P-11 and P-12 interlocks.

With one or more channels inoperable, the operator must verify that the interlock is in the required state for the existing unit condition. This action manually accomplishes the function of the interlock. Determination must be made within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is equal to the time allowed by LCO 3.0.3 to initiate shutdown actions in the event of a complete loss of ESFAS function.

If the interlock is not in the required state (or placed in the required state) for the existing unit condition, the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

Placing the unit in MODE 4 removes all requirements for OPERABILITY of these interlocks.

BRAIDWOOD - UNITS 1 & 2 B 3.3.2 - 50 Revi sian 88

ATTACHMENT 5 Markup of Technical Specifications Bases Pages for Byron Station, Units 1 arid 2 Byron Station, Units 1 and 2 Facility Operating license Nos. NPF-37 and NPF-66 AFFECTED TECHNICAL SPECIFICATIONS BASES PAGES (NOTE: TS Bases pages are provided for information only.)

B 3.3.1 -40 B3.3.1-41 B 3.3.1-42 B 3.3.1-45 B 3.3.1-46 B 3.3.2-43 B 3.3.2-44 B 3.3.2-49 B 3.3.2-50

BASES RTS Instrumentation B 3.3.1 ACTIONS (continued)

A Note to the ACTIONS restricts the transition from MODE 5 with the Rod Control System not capable of rod withdrawal and all rods fully inserted, to MODE 5 with the Rod Control System capable of rod withdrawal or all rods not fully inserted for Functions 18, 19, and 20 while complying with the ACTIONS (i.e., while the LCD is not met).

LCD 3.0.4 typically allows entry into MODES or other specified conditions in the Applicability while in MODE 5, however, the restriction of this Note is necessary to assure an OPERABLE RTS function prior to commencing operation with the Rod Control System capable of rod withdrawal or all rods not fully inserted.

BYRON - UNIT 1 & 2 0.1 and 0.2 Condition 0 applies to the Power Range Neutron Flux-High Function.

The NIS power range detectors provide input to the Rod Control System and the SG Water Level Control System and, therefore, have a two-out-of-four trip logic. A known inoperable channel must be placed in the tripped condition.

This results in a partial trip condition requiring only one-out-of-three logic for actuation. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the inoperable channel in the tripped condition is justified in Reference 13.

As an alternative to the above Action, the plant must be placed in a MODE where this Function is no longer required OPERABLE.

Seventy eight hours are allowed to place the plant in MODE 3. The 78 hour9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> Completion Time includes 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for channel corrective maintenance and an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for the MODE reduction as required by Required Action D.2. This is a reasonable time, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging plant systems.

If Required Actions cannot be completed within their allowed Completion Times, LCD 3.0.3 must be entered.

~

The Required Actions are modified by tw& Not57 The first Note applies to Func!ions that have installed bypass capability. The Note allows placing one channel in bypass for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing surveillance testing, and setpoint adjustments when a setpoint reduction is required by other_Technical Specificati~ns. The second Note ?P9lies to Funet1ons that do not have 1nstali-ed bypass eapabHtty.

This Note allows placing the inoperable channel in bypass for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> '1ihi 1 e performing survei 11 a nee testing or B 3.3.1 40 Revision -78

BASES RTS Instrumentation B 3.3.1 ACTIONS (continued) setpoint adjustments of other channels.

When survei 11 a nee testing is performed for functi ens 'n'i th i nstal1 ed bypass test capabi 1i ty under the Required Action Note, the appropriate TS Condition is entered, and the Required Action Note is applied, allowing an inoperable channel to be placed in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The Completion Time starts after the time in the Required Action Note expires, providing the equipment remains removed from service or bypassed.

If the surveillance time exceeds 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the Required Action would have to be performed (e.g., place channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />.)

In addition, for channels Hith installed bypass test capability, if a channel is discovered inoperable, the bypass test capability could be utilized during troubleshooting prior to expiration of the appropriate TS Condition Required Action Completion Time to place the channel in trip. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference 13.

the channel may be placed in a E.1 and E. 2 bypass condition 1-------"-

Condition E applies to the following reactor trip Functions:

Power Range Neutron Flux-Low; Overtemperature ~T; Overpower ~T; Power Range Neutron Flux-High Positive Rate; BYRON - UNIT 1 & 2 Pressurizer Pressure-High; and SG Water Level-Low Low.

A known inoperable channel must be placed in the tripped condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Placing the channel in the tripped condition results in a partial trip condition requiring only one-out-of-three logic for actuation of the two-out-of-four trips. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the inoperable channel in the tripped condition is justified in Reference 13.

If the inoperable channel cannot be placed in the trip condition within the specified Completion Time, the unit must be placed in a MODE where these Functions are not required OPERABLE.

An additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed to B 3.3.1-41 Revision +8

BASES RTS Instrumentation B 3.3.1 ACTIONS (continued) place the unit in MODE 3. Six hours is a reasonable time, based on operating experience, to place the unit in MODE 3 from full power in an orderly manner and without challenging plant systems.

~

The Required Actions are modified by twfr Not~ The first

~~~~ ~~~~es i~ F~~~!ions that have installed bypass b: ~ 0 The Note allows placing one channel in bth~ss for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing surveillance testing.

When surveillance testing is performed for functions vrith installed bypass test capability under the Required Action Note, the appropriate TS Condition is entered, and the Required Action Note is applied, allowing an inoperable channel to be placed in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The Completion Time starts after the time in the Required Action Note expires, providing the equipment remains removed from service or bypassed. If the surveillance time exceeds 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the Required Action would have to be performed (e.g., place channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />.) In addition, for channels '1di th installed BYRON - UNIT 1 & 2 bypass test capability, if a channe 1 is discovered inoperable, the bypass test capability could be utilized during troubleshooting prior to expiration of the appropriate TS Condition Required Action Completion Time to place the channel in trip. The 12-hour time limit is justified in Reference 13. the channel may be placed in a 1-----~

F. 1 and F. 2 bypass condition Condition F applies to the Intermediate Range Neutron Flux trip when THERMAL POWER is above the P-6 setpoint and below the P-10 setpoint and one channel is inoperable. Above the P-6 setpoint and below the P-10 setpoint, the NIS intermediate range detector performs the monitoring Functions. If THERMAL POWER is greater than the P-6 setpoint but less than the P-10 setpoint, 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is allowed to reduce THERMAL POWER below the P-6 setpoint or increase to THERMAL POWER above the P-10 setpoint. The provisions of LCO 3.0.4 allow entry into a MODE or other specified condition in the Applicability as directed by the Required Actions. Therefore, a MODE change is permitted with one channel inoperable whenever Required Action F.2 is used.

The NIS Intermediate Range Neutron Flux channels must be B 3.3.1-42 Revision +8

BASES RTS Instrumentation B 3.3.1 ACTIONS (continued)

K.1 and K.2 Condition K applies to the following reactor trip Functions:

Pressurizer Pressure-Low; Pressurizer Water Level-High; Reactor Coolant Flow-Low; Undervoltage RCPs; and Underfrequency RCPs.

With one channel inoperable, the inoperable channel must be placed in the tripped condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Placing the channel in the tripped condition results in a partial trip condition requiring only one additional channel to initiate a reactor trip above the P-7 setpoint. These Functions do not have to be OPERABLE below the P-7 setpoint.

The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the channel in the tripped condition is justified in Reference 13.

An additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed to reduce THERMAL POWER to below P-7 if the inoperable channel cannot be restored to OPERABLE status or placed in trip within the specified Completion Time.

Allowance of this time interval takes into consideration the redundant capability provided by the remaining redundant OPERABLE channel, and the low probability of occurrence of an event during this period that may require the protection afforded by the Functions associated with Condition K.

Ba, 9, and 10 The Required Actions are odified by two Notes.

The first BYRON - UNIT 1 & 2 Note applies to Functions that have installed bypass capability. The Note allows placing one channel in bypass for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing survei 11 ance testi n. The 12 and 13 second Note applies to Functions at o not ave 1nsta e bypass capability. This Note allows placing the inoperable channel in bypass for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing surveillance testing of other channels.

When surveillance testing is performed for functions with installed bypass test capability under the Required Action Note, the appropriate TS Condition is entered, and the Required Action Note is applied, allowing an inoperable channel to be placed in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The Completion Time starts after the time in the Required Action Note expires, providing the equipment remains removed from B 3.3.1-45 Revision -78

BASES RTS Instrumentation B 3.3.1 ACTIONS (continued) service or bypassed. If the surveillance time exceeds 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the Required Action would have to be performed (e.g., place channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />.)

In addition, for channels with installed bypass test capability, if a channel is discovered inoperable, the bypass test capability could be utilized during troubleshooting prior to expiration of the appropriate TS Condition Required Action Completion Time to place the channel in trip. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference 13.

L.1 and L.2 Condition L applies to Turbine Trip on Emergency Trip Header Pressure or on Turbine Throttle Valve Closure. With one channel inoperable, the inoperable channel must be placed in the trip condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

If placed in the tripped condition, this results in a partial trip condition requiring only one additional channel to initiate a reactor trip. If the channel cannot be restored to OPERABLE status or placed in the trip condition, then power must be reduced below the P-8 setpoint within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to place the inoperable channel in the tripped condition is justified in Reference 13.

The Required Actions have been modified by a Note that allows placing the inoperable channel in the bypassed condition for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing routine surveillance testing of the other channels. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit is justified in Reference 13.

M.1 and M.2 Condition M applies to the SI Input from ESFAS reactor trip and the RTS Automatic Trip Logic in MODES 1 and 2. These actions address the train orientation of the RTS for these Functions. With one train inoperable, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are allowed to restore the train to OPERABLE status (Required BYRON - UNIT 1 & 2 Action M.l) or the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Required Action M.1) is reasonable considering that in this Condition, the remaining OPERABLE train is adequate to perform the safety function and given the low probability of an event during this interval. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed to restore the inoperable RTS Automatic Trip Logic train to OPERABLE status is justified in Reference 13. The Completion Time of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (Required Action M.2) is reasonable, based on operating experience, to reach MODE 3 B 3.3.1 46 Revision 78

BASES ESFAS Instrumentation B 3.3.2 ACTIONS (continued)

The Required Actions are modified by a Note that allows one train to be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing, provided the other train is OPERABLE. This allowance is based on the reliability analysis assumption of WCAP-10271-P-A (Ref. 7) that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the average time required to perform channel surveillance.

D.1. D.2.1. and 0.2.2 Condition D applies to:

Containment Pressure-High 1; Pressurizer Pressure-Low; Steam Line Pressure-Low; Containment Pressure-High 2; Steam Line Pressure-Negative Rate-High; SG Water Level-Low Low; and SG Water Level-High High (P-14).

If one channel is inoperable, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are allowed to restore the channel to OPERABLE status or to place it in the tripped condition. Generally, this Condition applies to functions that operate on two-out-of-three logic or a two-out-of-four logic. Therefore, failure of one channel places the Function in a two-out-of-two configuration.

One channel must be tripped to place the Function in a one-out-of-two configuration that satisfies redundancy requirements.

The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed to restore the channel to OPERABLE status or to place it in the tripped condition is justified in Reference 15.

Failure to restore the inoperable channel to OPERABLE status or place it in the tripped condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requires the unit be placed in MODE 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 4, these Functions are no longer required OPERABLE.

BYRON - UNITS 1 & 2 B 3.3.2-43 Revision 62

BASES ESFAS Instrumentation B 3.3.2 ACTIONS (continued)

When survei 11 ance testing is performed for functi ens ~,*; th installed bypass test capability under the Required Action Note, the appropriate TS Condition is entered, and the Required Action Note is applied, allowing an inoperable channel to be placed in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The Completion Time starts after the time in the Required Action Note expires, providing the equipment remains removed from service or bypassed. If the surveillance time exceeds 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the Required Action would have to be performed (e.g., place channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />.)

In addition, for channels with installed bypass test capability, if a channel is discovered inoperable, the tJ,'pass test capabi 1 i ty caul d be utili zed,~

during troubleshooting prior to expiration of the appropriate TS Condition Required Action Completion Timet place the channel in trip. The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for testing is justified in Reference 15. th h

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E.l. E.2.1. and E.2.2 bypass condition Condition E applies to:

Containment Spray Containment Pressure-High 3; and Containment Phase B Isolation Containment Pressure-High 3.

None of these signals has input to a control function.

Thus, two-out-of-three logic is necessary to meet acceptable protective requirements. However, a two-out-of-three design would require tripping a failed channel. This is undesirable because a single failure would then cause spurious containment spray initiation. Spurious spray actuation is undesirable because of the cleanup problems presented. Therefore, these channels are designed with two-out-of-four logic so that a failed channel may be bypassed rather than tripped. Note that one channel may be bypassed and still satisfy the single failure criterion.

BYRON - UNITS 1 & 2 B 3.3.2 - 44 Revi sian +8

BASES ESFAS Instrumentation B 3.3.2 ACTIONS (continued)

J.l Condition J applies to the Auxiliary Feedwater Pump Suction Transfer on Suction Pressure-Low Function.

With one train inoperable, the associated auxiliary feedwater pump must be immediately declared inoperable. This requires entry into applicable Conditions and Required Actions of LCO 3.7.5, "AF System."

K.l. K.2.1. and K.2.2 Condition K applies to the RWST Level-Low Low Coincident with Safety Injection Function.

RWST Level-Low Low Coincident with SI provides actuation of switchover to the containment sump.

Note that this Function requires the bistables to energize to perform their required action.

This Condition applies to a Function that operates on two-out-of-four logic. Therefore, failure of one channel places the Function in a two-out-of-three configuration.

One channel must be tripped to place the Function in a one-out-of-three configuration that satisfies redundancy requirements.

If the channel cannot be returned to OPERABLE status or placed in the tripped condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the unit must be brought to MODE 3 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 5, the unit does not have any analyzed transients or conditions that require the explicit use of the protection function noted above. ~

The Required Actions are modified by tw& Notes. The first Note applies to Func!ions that have installed bypass capabtltty. The Note allows placing one channel in bypass for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while performing surveillance testing. ffle

~~:~~~ ~~;;b~~W~~s f~;:u~g!!o~i,!e:\\~~c~~: ~=~e;!~;!~!~i~

channel in bypass for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while perforlfling surveillance testing of other channels.

BYRON - UNITS 1 & 2 8 3.3.2-49 Revision -78

BASES ESFAS Instrumentation B 3.3.2 ACTIONS (continued)

When surveillance testing is performed for functions with installed bypass test capability under the Required Action Note, the appropriate TS Condition is entered, and the Required Action Note is applied, allowing an inoperable channel to be placed in bypass for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The Completion Time starts after the time in the Required Action Note expires, providing the equipment remains removed from service or bypassed.

If the surveillance time exceeds 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the Required Action would have to be performed (e.g., place channel in trip within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3 within 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />.)

In addition, for channels.,,ith installed bypass test capability, if a channe 1 is discovered i noperab 1 e, the bypass test capability caul d be utili zed during troubleshooting prior to expiration of the

~

appropriate TS Condition Required Action Completion Time t place the channel in trip. This is acceptable based on the results of Reference 15.

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L.l. L. 2.1 and L. 2. 2 bypass condition Condition L applies to the P-11 and P-12 interlocks.

With one or more channels inoperable, the operator must verify that the interlock is in the required state for the existing unit condition. This action manually accomplishes the function of the interlock. Determination must be made within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is equal to the time allowed by LCO 3.0.3 to initiate shutdown actions in the event of a complete loss of ESFAS function.

If the interlock is not in the required state Cor placed in the required state) for the existing unit condition, the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

Placing the unit in MODE 4 removes all requirements for OPERABILITY of these interlocks.

BYRON - UNITS 1 & 2 B 3.3.2 - 50 Revision +8