ML20216D914

Forwards Revised Description & Safety Analysis Pages & Mod Proposed TS mark-up Pages Re 980324 Request for Amends to Licenses NPF-37 & NPF-66,revising TS Surveillance Requirements 4.6.1.1.c,4.6.1.2.a,4.6.1.2.b & Bases

ML20216D914
Person / Time
Site:	Byron
Issue date:	04/09/1998
From:	Graesser K COMMONWEALTH EDISON CO.
To:	NRC
Shared Package
ML20216D918	List: ML20216D914 ML20216D943
References
BYRON-98-0114, BYRON-98-114, NUDOCS 9804160031
Download: ML20216D914 (5)

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April 9,1998 l

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LTR: BYRON 98-0114 FILE: 2.01.0301 United States Nuclear Regulatory Commission Washington, D. C. 20555 l

Subject:

Revised Technical Specification Submittal Byron Nuclear Power Station, Units I and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Nos. 50-454 and 50-455 Containment Leak Rate Testing

Reference:

Letter from K. L. Grac:.ser (Commonwealth Edison) to NRC Document j Control Desk dated March 24,1998 j In the referenced submittal, Commonwealth Edison Company (Comed) proposed to {

revise Technical Specifications (TS) Surveillance Requirements 4.6.1.1.c,4.6.1.2.a, 4.6.1.2.b, and the Bases to permit a deferral that allows the 10 CFR 50, Appendix J Type A testing of the Byron Unit 2 containment to be deferred 10 months. The purpose of this letter is to provide a revised submittal that incorporates a word change recommended by NRC Staff. Specifically, the word " exemption" that appeared in the j referenced proposed TS amendment is being replaced with " exception." 1 I

The two pages from the " Revised Description and Safety Analysis Pages" section of the referenced submittal that contained the word " exemption" have been modified and are provided in Attachment A. The modified proposed TS mark-up pages provided in l Attachment B to this letter will replace in entirety those originally provided in the )

March 24th submittal.

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The changes in wording provided in this submittal have been reviewed and approved by both On-site and Off-site Review in accordance with Comed procedures. The no significant hazards consideration evaluation and the Environmental Assessment provided hp j in the previous submittal are unaffected by these wording changes.

l l Comed respectfully requests the NRC review and approve this license amendment request by April 27,1998, to support the B2R07 outage scheduling activities at Byron.  !

9804160031 990409 PDR ADOCK 05000454 P PDR (p:wooystrswsu a 14.aoc)  !

A 1:nk om company 1

Byron Ltr #98-0114 L April 9,1998 l Page 2 l

l l To the best of my knowledge, the statements contained in this document are true and j l correct. j 1

Please address any comments or questions regarding this matter to our Nuclear  !

Regulatory Services Department.

Sincerely, j I

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e, K. L. Graesser Byron Site Vice President KLG/LL/rp Attachments A - Revised " Description and Safety Analysis Pages" B - The revised proposed changes to Byron Technical Specifications cc: Regional Administrator-Rill Byron Project Manager-NRR Senior Resident inspector-Byron Office of Nuclear Safety-IDNS l

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• l NITACllMENT A Revised Description and Safety Analysis Pages i

Reference:

Letter from K. L. Graesser (Commonwealth Edison) to NRC 1,ocument

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Control Desk dated March 24,1998  !

Affected Pages: Attachment A, Second Page, Section E, first sentence.

Attachment C, First Page, first sentence l 1

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10 CFR 50.12 to allow Comed to perform Type A testing of Byron Unit 2 and l Braidwood Unit 2 containments at least once per 10 years based on a single successful Type A test, rather than two successful Type A tests. This request was converted, at the request of NRC Staff, to a License Amendment request (Referenced Letter) to again adopt the 10 year test interval for Unit 2 at Byron and Braidwood. Approval of this I request would have allowed the next Type A test to be performed in September,2003 for Byron 2.

Based on discussions with the Staff, it was apparent that the Referenced amendment may not have been granted prior to the Byron Unit 2 surveillance expiration date of Dccember 1998. As a result, Byron would be forced to perform the test during the B2R07 outage or conduct a forced outage to perform the surveillance. Therefore, because this test was

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never included in the B2R07 outage and because it is resource and schedule intensive, j Comed is providing this additional amendment request to defer the 10 CFR 50, Appendix {

J Type A testing of the Byron Unit 2 containment approximately 10 months. j Past containment Type A testing and surveillance practices demonstrate that the I underlying ptupose of 10 CFR 50, Appendix J. Option B can be met with an extended

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Type A test interval. Postponing the performance of a Type A test to the next refueling outage for Byron 2 will not impact the health and safety of the public.

E. DESCRIPTION OF TIIE PROPOSED CIIANGE Comed proposes to revise TS Surveillance Requirement 4.6.1.1.c ,4.6.1.2.a,4.6.1.2.b, and the Bases to note that requirements are modified by an approved schedular exception in the ILRT testing interval. The Bases for 3/4.6.1.2 will describe the approved extension.

Specifically, Byron Unit 2 would extend the ILRT test interval by 10 months to the Fall of 1999. The changes are shown in Attachment B.

I F. BASES FOR YIIE PROPOSED CIIANGE Comed believes that extending the Type A test interval by 10 months for Byron Unit 2 will not impact containment leakrate and will not pose any undue risk to the public. The integrity of the Byron 2 containment is demonstrated through prior testing history, the design of the secondary side steam generator manways, operating practices related to secondary side leakage, and the behavior of the secondary side of the steam generators during accident conditions. In particular:

Tyne A Test Performance Histon The first Byron Unit 2 Type A test following the successful pre ... ional test was conducted in September 1990. During the operating cycle pr a umg the test, a steam generator secondary manway leak developed. The test was performed in the as-found condition, so no repairs were affected prior to the test. During this l test, a steam generator manway leaked. The leakage was isolated by closing the l Main Steam Isolation Valve and pressurizing the secondary side of the steam l j generator to approximately one psig below the containment test pressure. Initially the test was considered successful since the steam generator pressure is greater k \nla byrbwJ drt_ byron doc

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i l ATTACllMENT B REVISED MARKED UP PAGES FOR PROPOSED CilANGES TO APPENDIX A TECilNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSES NPF-37 and NPF-66, l i

IlYRON STATION UNITS 1 & 2

Reference:

Letter from K. L. Graesser (Commonwealth Edison) to NRC Document l Control Desk dated March 24,1998 l

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