ML20202C128

Forwards Revised Response to Request for Addl Info for Improved TS Sections 3.0,3.7 & 3.9,per NRC 971205 Ltr

ML20202C128
Person / Time
Site:	Byron, Braidwood
Issue date:	02/06/1998
From:	Tulon T COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9802120171
Download: ML20202C128 (73)

Text

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February 6,1998 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

Subject:

Byron Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Nos 50-454 and 50-455 Braidwood Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-72 and NPF-77 NRC Docket Nos. 50-456 and 50-457 Revision to " Response to Request for Additional Information for ITS Sections 3.0,3.7, and 3.9"

References:

(1) G. Stanley and K. Graesser (Commonwealth Edison) to NRC letter dated December 13,1996 (2) R. Assa (NRC) to 1. Johnson (Commonwealth Edison) letter dated December 5,1997 (3) T. Tulon (Commonwealth Edison) w NRC letter dated January 27,1998 With Reference 1, Comed submitted an application for amendment to adopt the Improved Technical Specifications (ITS). Reference 2 contained a Request for Additional Information ('RAI) from the NRC staff pertaining to ITS Sections 3.0,3.7, and 3.9. The Comed response was transmitted with Reference 3. Comed has identified the need to revise the Reference 3 Response. The revised response is provided t.s an attachment to this letter.

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DR p ADOCK 05000454 PDR A t;nicom Company

U.S. Nuclear Regulatory Commission February 6,1998 4

, Please address any comments or questions regarding this Inatter to Dave Chrzanowski,

,. Nuclear Licensing Department, Sincerely,  :

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r thy J. Tulon ite Vice President Braidwood Nuclear Generating Station Attachment 1: Revision to "v.. 4ponse to RAI for ITS Sections 3.0,3.7, and 3.9" cc: Regional Administrator - Region III, NRC Byron Project Manager - NRR Braidwood Project Manager - NRR '

Senior Resident Inspector - Braidwood Station Senior Resident Inspector - Byron Station Office of Nuclear Facility Safety - IDNS o:hrc.. 980llyt&w s

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Attachment 1 3

Revision to " Response to NRC RAI Report on the Comed ITS Submittal"

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Respo se 13 NRC RAI Dated 12/05/97 05-reb-9s NRC RAI Numt:*r - NRC lisued Date RAI Status q 3.0-01 12/5/97 - Open NRC Action Required NRC Description ofissue 3.0 DOC LAI CTS 3.0.5 and 4.0.6 Both Byron and Braidwood' arc dual unit sites; therefore, CTS 3.0.5.a and b are essential to underrtanding how the LCOs, in the CTS and now in the ITS, apply equally or individually to each unit. De STS was developed based upon a single unit -

site. The adaption of the STS to a multiple unit site occurs during this conversion which strives to maintain the current -

licensing basis of the CTS. CTS 3.0.5 and CTS 4.0.6 must be retained as written except for CTS 3.0.5.c which must delete

" footnotes". His is because the STS only permits Notes in the body of the requirements. Camment: Identify all Unit I and 2 shared systems or shared supporting systems to the ITS LCOs. DOC LAl must be rewritten as an administrative change to retain CTS 3.0.5 and CTS 4.0.6.

Comed Response to issue No change. The Byron /Braidwood submittal is consistent with the submittals of other dual unit sites which do not retain the CTS LCO and SR pertaining to dual unit applicability. Comed believes that DOC 3.0 LAl adequatelyjustifies relocating this information to the TRM. The ITS LCOs and Bases provide adequate clarification of dual unit operating requirements, restrictions, and exemptions. Comed continues to pursue this change, p

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Response to NRC RAI D:ted 12/05/97 Os-r2b-98

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,x NRC RAI Number NRC lisued Date -.RAI Status-l  ; 3.0-02 12/5/97 Open NRC Action Required -

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J NRC Description of issue 3.0-2 JrD BP)

Bases for ITS Section 3.0 The following proposed editorial differences between the STS and ITS Bases are not accepted because they are no clearer than the STS wording and in some cases change the meaning.

Page B 3.0 2 and LCO 3.0.2

+ "In this instance," reph.ces "w here this is the case"

. "and the new LCO is not met" is added a

"new" rep' aces " associated" Page 113.0 , aad LCO 3.0.3 "no single Condition or combination ... that corresponds" replaces "no combination . . that exactly corresponds"

." . warrante<' in such cases, the Conditions corresponding to such combinations state that LCO 3.0.3 shall be entered" replaces ". . warranted; in such cases, the ACTIONS speci0cally state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered"

• "LCO" replaces "Specl0 cation" Page B 3.0-4 and LCO 3.0.3

• " remedial measures" replaces " appropriate remedial measures" Page B 3.0-5 and LCO 3.0.4

. "different MODE" replaces " MODE" Page B 3.0-6 and LCO 3.0.5

+ "LCO" replaces "Speci0 cation" Page B 3.0-8 and LCO 3.0.6 m * " systems' Conditions ..." replaces " systems' LCOs' Conditions . ."

s I Page B 3.0-13 and SR 3.0.3 l " delay period" replaces " time limit" l Page B 3.0-13 and SR 3.0.3

' " .. MODE changes imposed by Required Actions or a reactor trip." replaces " . MODE changes imposed 1 y Required ,

Actions "

Comment: These differences are notjustifiable on a plant-specinc or editorial basis, Revise the Bases for ITS Section 3.0 to adopt the STS language for the cases listed.

Comed Response to issue No change. In comparing Comed's proposed Bases editorial ditTerences, the only changes are wording preferences which are strictly editorial. There is no technical or operational benefits gained in using the STS wording Comed has made these changes to provide consistency throughout ITS, and to reflect NUREG philosophy and terminology. Comed elects to maintain our current wording, and continues to pursue this change.

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Itsponse ta NRC RAI D:ted 12/05/97 Os-Ich-98

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I NRC RAI Number NRC issued Date RAI Status

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-3.0-03 12/5/97 Open NRC Action Required NRC Description of issue -

3.0-03 JFD BC2 Bases for ITS LCO 3.0.1 Proposed differences from the Bases for STS LCO 3.0.1 are based on TSTF 08, Rev.1. Ilowever, this STS generic change proposal was superceded by TSTF 08, Rev 2, which the NRC approved on 8/20/97 Comment: Revise the Bases for ITS LCO 3.0.1 to conform to the Bases for STS LCO 3.0.1 as modined by TSTF 08, Rev.1.

Comed Response to issue TSTF 8, Revision 2, will be incorporated, and Bases JFD 3.0-C2 will be revised to state,"This change is consistent with NUREO 1431, as modified by TSTF 8, Revision 2. This change will be provided in our comprehensive ITS Section 3.0 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.0 RAI, NRC RAI Number NRC issued Date RAI Status 3.0-04 12/5/97 Open NRC Action Required NRC Descri,ntion of issue 3.0-4 JFDs Pi and C5 JFDs BC7 and P2 ITS LCO 3.0.4

. Bases for ITS LCO 3.0.4, STS Bases markup page B 3.0-6 (1) The last sentence of the first paragraph ofITS LCO 3.0.4 and th e last sentence of the paragraph at the top of the referenced page in the STS Bases markup differ from the STS,'as follows. In the LCO, the ITS omits the words "or that are O(' part of a shutdown of the unit;" in the Bases the ITS replaces the phrase "any unit shutdown" with "a shutdown performed in response to the expected failure to comply with ACTIONS." These differences are based on TSTF 103, which has not yet been approved by the NRC, Comment: Revise the submittal to adopt the STS wording.

(2) The ITS replaces the next to last paragraph in the Bases for STS LCO 3.0.4 with a paragraph proposed by TSTF 103.

Because there are no Mode restrictions pronosed for LCO 3.0.6 in the ITS, nicther of these paragraphs are needed. They should both be omitted. Comment: Revise the Bases to omit the paragraph described.

Comed Response to issue No change. As discussed in LCO JFD 3.0-PI, this change is consistent with the current licensing basis of the plant and consistent with the requirements denoted in the Reviewer's Note in NUREG-1431, as modified by TSTF 103. Incorporation of the Staf1's comment is not ajustinable change. Corc,Ed continues to pursue this change.

NRC RAI Number NRC lssued Date RAI Status 3.0-05 12/5/97 Open - NRC Action Required NRC Description of Issue 3.0-05 JFD C3 JFD BC5 1TS LCO 3.0.5

- ITS LCO 3.0.5 differs from STS LCO 3.0.5 because it incorporates wording changes based on TSTF-01, Rev.1. NRC rejected this STS generic change proposal on 9/16/96. Comment: Revise the submittal to adopt STS LCO 3.0.5.

Comed Response to issue p Comed will withdraw TSTF-1, Revision 1. This change will be provided in our comprehensive ITS Section 3.0 closeout d submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.0 RAl.

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. R:spo :se to NRC RAI D:ted 12/05/97 05-F2b-98 NRC RAI Number NRC lssued Date RAI Status O 3.0-06 12/5/97 Open NRC Action Required NRC Description ofissue 3.0-06 JFD C3 (?)

JFD BC10 ITS LCO 3.0.6 11ases for ITS LCO 3.0.5 The ITS replaces the STS words " testing required" with " required terting" in LCO 3.0.6. It could not be determined which JFD applies to this difference. In addition, the ITS replaces the STS term "SR" with " required testing" in several places in -

- the Bases for LCO 3.0.5. In one case in the Bases, the ITS replaces the STS phrase " allowed SRs" with " required testing to demonstrate Operability." These diftres.ces from the STS Bases are based on not-approved-by the-NRC WOG 77, w hich is referenced by JFD BCIO. Comment: The term " required testing" is not defined and could be construed to mean testing other than required by TS. The existing language in the STS is clear. Revise the Bases to adopt the STS wording.

Comed Response to issue ne changes to the Bases were made in accordance with WOG 77 which was approved by the Staff as TSTF 165. TSTF 1, Revision I, which made the corresponding changes to the LCO, was rejected. Derefore, for consistency with the approved .

Bases changes, Comed will pursue the LCO changes on a plant specific basis, in aadition, Bases JFD 3.0-C10 will replace "WOG-77" with "TSTF 165."

NRC RAI Number NRC issued Date RAI Status 3.0-07 12/5/97 Open - NRC Action Required l NRC Description of issue 3.0-07 JFD C8 ITS LCO 3.0.6

( i in the first paragraph of LCO 3.0.6, the ITS replaces the STS phrase " additional evaluations and limitations may be required" with "an evaluation shall be performed." This difference is based on not-approved-by the-NRC WOG 78.

Comment: STS LCO 3.0.6 is an industry creation and should be adopted as written. Revise ITS LCO 3.0.6 to conform to the STS wording.

Comed Response to issue The changes to the Bases were made in accordance with WOG 78 which was approved by the Staff as TSTF-166. In addition, LCO JFD 3.0-C8 will replace "WOG 78" with *TSTF-166." Comed continues to pursue this change.

NRC RAI Number NRC issued Date RAI Status 3.0-08 12/5/97 Open - NRC Action Required NRC Description ofissue 3.0-08 Bases for ITS LCO 3.0.6 The Bases of LCO 3.0.6 in NUREG-1431, Rev.1 has been revised with an example illustrating the application of the Safety Function Determination Program. This revision was based on TSTF-71, Revision 1, approved by the NRC on 10/2/97. The Bases for ITS LCO 3.0.6 did not propose to adopt this STS generic change. Comment: Revise the Bases for ITS LCO 3.0.6 to incorporate TSTF-71, Revision I, since it has been approved.

Comed Response to issue The Bases will be revised to incorporate TSTF 71, Revision 1. This change will be provided in our comprehensive ITS Section 3.0 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.0 RAI.

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Response is NRC RAI D:ted 12/05/97 05-reb-98 NHC RAI Number NRC issued Date RAI Status 7, -3.0-09 12/5/97 Open.NRC Action Required NRC Description ofissue 3.0-09 JFD BPl Bases discussion of LCO 3.0.7, STS markup page B 3.0-9 in the second paragraph, the deletion of The second sentence, " Compliance with Test Exception LCOs is optional." is not adopted.- Comment: This is not a justifiable plant specific or editorial difTerence. Revise the submittal to adopt this sentence.

Comed Response to issue Com Ed .<ill adopt the sentence. This change will be provided in our comprehensive iTS Section 3.0 closeout submittal revision unon NRC's concurrence with the Comed Responses to the ITS Section 3.0 RAl. (Correction Note: The word

" deletion" in the NRC Description ofissue should be " addition.")

i: NRC RAI Number NRC issued Date RAI Status 3.0-10 12/5/97 Open NRC Action Required NRC Description ofIssue 3.0-10 JFD P2 JFD BP5 (and reference to NRC-rejected TSTF-4I)

ITS LCO 3.0.7 and associated Bases ITS proposes to replace the STS term " Test Exception LCOs" with "Special Exception LCOs" in one place in the Bases for ITS LCO 3.0.7, and with " Exception LCOs" elsewhere in LCO 3.0.7 and the associated Bases. JFD P2 basis this difference

-p on consistency with TSTF-41, which the NRC has rejected, and an apparent need to expand the provisions of LCO 3.0.7 to

- apply "to more than testing such as special tests and operations." Comment: STS generic change proposal TSTF 41 was rejected by the staff on 5/8/97. Revise ITS LCO 3.0.7 and associated Bases to conform to the STS.

Comed Response to issue -

The word "Special" in the Bases Markup for LCO 3.0.7 will be deleted. The reference to TSTF-41 in Bases JFD 3.0-P5 will -

be deleted. Comed continues to pursue this change asjustified in LCO JFD 3.0-P2 and Bases JFD 3.0 P5. (Correction Note: Bases JFD 3.0 P5 references TSTF 41, not JFD 3.0-P2.)

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Response ta NRC RAI D:ted 12/05/97 os reb 98 NRC RAI Number NRC lasued Date RAI Status 3.0-11 12/5/97 Open . NRC Action Required NRC Description ofissue 3.0-l 1 JFD BC6

, Bases for ITS SR 3.0.2 The third paragraph of the STS Bases for STS SR 3.0.2 presents an example of a surveillance for which the allowance to extend the specified Frequency by 25% would not be permitted (a containment leakage rate testing surveillance), STS generic change proposal TSTF 52 revises this example consistent with the adoption of Option B to Appendix J and the -

creation of an STS administrative controls programmatic requirement, the Containment Leakage Rate Testing program.

- The ITS proposes to adopt the STS changes proposed in TSTF-52, Comment: Staff has not yet approved TSTF 52, in -

addithn, the proposed change to the Bases obscures the point trying to be made the reason the 25% allowance does not apply, Revise the submittal consistent with the plant specific resolution ofissues related to adopting Option B, but make sure the Bases clearly explain w hy the 25% allowance does not apply to the surveillance described in the example.

- Comed Response to issue in the Bases for SR 3.0.2, to clarify the reason that the 25% extension does not apply, Comed will retain the portion of

--TSTF 52 which deleted, "The requirements of regulations take precedence over the TS. The TS cannot in and of themselves extend a test interval specified in the regulations."

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- Response to NRC RAI Dated 12/05/97 os reb-98 NRC RAI Number NRC lest:el Date = RAI Status -

3.7,1 01 12/5/97 Open.NRC Action Required NRC Description of issue -

3,7.11 DOC A.I DOC A.3 -

DOCL,1 JFD B.!

- JFD B.2 JFD B.22 -

JFD C.3 JFD liases B.1 JFD Bases B.21 JFD Bases C.2 JFD Bases P.I CTS 3.7.1.1 CTS 3.7.1.1 ACTIONS CTS Table 3.71 STS LCO 3,7.1 STS 3.7.1 ACTION A STS 3,7.1 TABLE 3.7.1. l ITS LCO 3.7.1 ITS 3,7.1 ACTION A ITS 3.7.1 TABLE 3,7.1 land Associated Bases -

CTS 3/4,7,1,1 has been modined by a number of changes designated as A.3 Tl4ese changes were approved by the Staffin Amendment 79 for Braidwood and Amendment 87 for Byron dated 4/15/97, CTS 3,7,1,1, and its associated ACTION

.\ statements as modified by the approved AJ and CTS TABLE 3.7 1 have been further modified to reflect the changes made to STS LCO 3.7,1, STS 3,7.1 ACTION A and STS 3,7.1 TABLE 3,7.1 1 by WOG-83. Dese changes are designated as A.1 and L.1 in the CTS markup and B.l., B.2, B.22, C.3, Bases B.1, Bases B.21, Bases C.2 and Bases P.1 in the ITS markup.

WOG-83 has not been submitted te the staff by the Owner's Grcup for review and is thus, consideied to be a beyond scope

. of review item for this conversion. Comment: Delete this generic change, revise the CTS and STS/ITS markups to either reflect the current CTS as modined by A.3 or the STS, and provide the appropriate discussions andjustifications for the

. changes.

Comed Response to issue.

2/6/98 Corrected Response: No change. Byrort /Braidwood originally introduced the changes proposed in WOG-83 to the Westinghouse Owner's Group (WOG) in October 1996.- Based on input from Westinghouse and other Westinghouse plams, WOG-83, Revision I, was created and is currently under TSTF review. Comed continues to pursue the Westinghouse-speci0c generic cnanges proposed in WOG 83 on a plant specine basis.-

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R:sponse to NRC RAI DIted 12/05/97- 05-Feb-98 NRC RAI Number NRC issued Date RAI Status 3.7.1-02 12/5/97

( Open NRC Action Required NRC Description ofissue 3.7.1 2 JFD 11ases C.4 STS B3.7.1 Bases IIACKGROUND ITS 133.7.1 Bases BACKGROUND ITS B3.7.111ases BACKGROUND modilles STS B3.7.1 Bases BACKGROUND in accordance with TSTF-44 Revision

1. TSTF 44 Rey, O was rejected by the staff and TSTF-44 Revision I has not been subm.tted for staff review. Thus this change is considered a beyond scope of review item for this conversion. See item Number 3.6.3 1. Delete this generic change.

Comed Response to issue No change. Comed disagrees that the paragraphs added to the Background and Applicable Safety Analysis Sections dthe flases for LCO 1.7.1 are beyond scope. The CIV function of the MSSVs is addressed by LCO 3.6.3 in both CTS and ITS.

One of the several changes TSTF-44 proposed, provided additional informatior in Bases B.3.7.1. The specific statements Comed added were,."The MSSVs aho serve as Containment isolation Valves (CIVs); however, the ClV function is addressed in LCO 3.6.3, " Containment Isolatior, Valves"," and "The MSSVs are also credited as CIVs (refer to LCO 3.6.3)." These statements are being maintained in the Bases since they do not change any technical information or intent as provided by NUREG 1431. The changes do not aher any Required Actions, Completion Times, or Surveillance Testing

. Frequencies. The only intent is to provide a more accurate description of both the Byror and Braidwood plant designs and to better assist the operators in locating associated LCOs Althcugh originally part of TSTF-44, the human fac.ars benefit and enhancement obtained from these changesjustifies them being pursued on a plant specific basis. Bases JFD 3.7-C4 will be deleted and a 'P' Bases JFD created tojustify these changes. Comed continues to pursue this change. (See RAI 3.7.4 3.)

NRC RAI Number NRC issued Date RAI Status

..() 3.7.1 03 12/5/97 Open - NRC Action Required

- NRC Description of issue 3.7,13 None STS '33.7.1 Bases LCO ITS B3.7.1 Bases LCO ITS B3.7.1 Bases SR 3.7.1,1 ITS '33.7.1 Bases - LCO relocates the third paragraph of STS B3.7.1 Bases - LCO which states "The lift settings, . . and i pressure" to ITS B3.7.1 Bases SR 3.7.1.1. Nojustification is prowded for this generic change. Comment: Delete this

. generic change or provide a discussion and justification for the relocation based on current licensing basis, system design or operational constraints.

" Comed Response to issue Comed will develop a 'p' Bases JFD to describe moving the third paragraph of the LCO Section of the Bases to the end of

' the second paragraph of the Bases for SR 3.7.1.1 in the Surveillance Requirements Section of the Bases for LCO 3.7.1.

This change will be provided in our comprehensive lTS Section 3.7 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

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1 Response to NRC RAI Dated 12/05/97 es reb-9s NNUE4TNumber ~ NR6 issued Date li I~Sintus 3.7.2-01 12/$/97 Open

• NRC Action Required l NRC Description ofissue 3.7.2. I DOC A.2 >

DOC A.10 t DOC M.2 DOC 1.6 DOC L7

• JFD C.6

- JI D C.8 JFD liases 11.2

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JFD liases C.7 ' ,

JFD flases C.8  :

CTS 3.7.1.5 ACTIONS STS 3.7.2 ACTIONS and Associated liases ITS 3.7.2 ACTIONS and Associated Bases CTS 3.7.1 $ ACTIONS have been modified by a number of changes designed A.2, A.10, M.2, L6, L 7 to redect the changes made to STS 3.7.2 ACTIONS and Associated liases by TSTF.102 and WOO 64. These changes are designed C.6  ;

and llases C,7 for TSTF 102 and C.8, Bases 11.2 and Bases 11.8 for WOO.64. TSTF 102 has been rejected by the staff while it is our understanding that WOG 64 has been withdrawn. Comment: Revise the CTS /ITS rnarkups to delete these generic change and provide the appropriate CTS /ITS markups to tenect the CTS or the STS. Provide any additional discussions 4

andjustincations for the changes, i Comed Response to issue Comed will revise the ITS submittal to delete the changes proposed by TSTF 102. Ilowever, WOO-64 is under TSTF consideration and Comed continues to pursue the change on a plan *. speGric basis. WOG 64 was created for consistency with the changes to NUREO LCO 3.6.3 (CIVs) Condition C far extending the Compl: tion Time to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This change .

was approved by the NRC in TSTF.30, Revision 2, . ' May ;997. 'Ihe just10 cation is that the MSIVs fall into the same

- classl0 cation of valves that NUREO LCO 3,6.3 Condition C valves fall into. This change will be provided in our i

- comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

NRC RAI Number NRC issued Date RAI kaius

3.7.2 02 12/$/97 Open + NRC AcMon Required

- NRC Description ofIssue

- 3.7.22 - DOC A.10 CTS 3.7.1.5 ACTION . MODE 1 ITS 3.7.2 ACTION B CTS 3.7.1.5 ACTION MODE 1 requires that if one MSI / cannot be restored to OPERABLE status in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Qen be in 2

ilOT STANDBY (MODE 3)in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in IIOT SilVTDOWN in another 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ITS .'.? 2 ACTION B only requires ,

the unit in MODE 2 for one inoperable MSIV not restored within the Completion Time. 7his is not an administrative change as identined by A.10 but a less restrictive change. Comment: Revise the submittal, provide additional discussion and. technical justi0 cation for this Less Restrictive change.

Comed Rei.ponse to issue -

- No change. Comed disagrees. CTS 3.7,1.5 " Action for MODE 1" requires that if one MSIV cannot be restored to

. OPERABLE status in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, then action must be taken to place the unit in llOT STANDBY (MODE 3) in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Once the unit reaches MODE 2. CTS 3.7.1.5 " Action for MODES 2 and 3" allows subsequent operation in MODE 2 or 3 provided the MSIV is closed. Otherwise, the unit must continue shutting down in accordance with the Action for MW31.

d Comed continues to pursue this change.

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NHC RAI Number NHC issued Date RAI Status l 3,7.2 03 12/$/97 Open. NRC Action Required

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.j NHC pescription ofissue 3.7.23 DOC M.3 JFD P.6 JFD liases p.7

CTS 4.7.l.$ -

$13 SR 3.7.2.1 '

1TS SR 3.7.2.1 ITS SR 3.7.2.2 and Associated liases CTS 4.7.1.5 requires the veri 0 cation of full closure of each MSIV in 5 seconds w hen tested in accordance with CTS 4.0.5.  ;

.The equivalent STS SR for this CTS tequirement is STS 3.7.2.1. The ITS markup breaks STS SR 3.7.2.1 into tw o SRs . ITS SR 3.7.2.1 (verincation of closure is $ seconds) and ITS SR 3.7.2.2 (verification of closure by actual or simulated signal).

The justification for this change (p.6)is that if the valve fails the closure time SR, there is no need to perform a full actuation test (11S SR 3.7.2.2) since closure time can be measured without this test. This change is considered to be a -

generic change whkh is beyond the scope of review for this conversion. See item Number 3.7.3 2. Comment: Delete this -  !

generic change.

! Comed Response to lasue No change. Comed disagrees that this is a beyond scope change since it does not change any technical requirements, testing procedures, or isolation times supporting the UFSAR analysis. This change is consistent with current licensing basis and the methodology currently used to test the subject valves. The CTS requires, Each MSIV shall be demonstrated 2

OPERAllLE by verifying full closure within 5 seconds when tested pursuant to Specification 4.0.5. This provided the  !

means of testing the full closure of the MSIVs within their Ul'SAR required time.1he CTS testing did cot restrict this

• l testing solely on using the actuated or simulated signals. Ilased on the Braidwood and Ilyron design basa, wrifying that the ,

valves fully close within the required time is adequate. STS SR 3.7.2.1 requires verifying that each MSIV actuates to the ,

% isolation position on an actual a simulated actuation signal. Although an approved method, this requirement is by no  ;

means the only test verifying that the MSIVs close within the time supporting the accident analysis. Comed chose to divide the STS SR into two separate SRs. 'the reason is that if an alternate, but reliable and accepted, method is used and the valves do not met the required stroke time, then it is unnecessary to cycle the MSIVs an additional timejust for the sake of  ;

, using an actual or simulated actuation signal. Iloth ITS SR 3.7.2.1 and 3.7.2.2 provide the same level of assurance and . .

verification that the MSIVs are OpERAllLE with regard to their closure time. Comed continues to pursue this change. i

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10

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Response to NRC RAI Dated 12/05/97 os-reb.9s NRC RAI Number NRC lasued Date RAl Status  !

3.7.2 04 12/$/97 Opei. NRC Action Required NRC Description of losue [

3.1.24 JFD P.28 t

JFD !!ases P.$

JFD liases P.6 i

CTS 3/4.6.3 '

C15 3/4.7.1.$

ITS 3.6.3 APPLICAlllLi1Y STS 3.7.2 APPLICAlllLl1Y ITS 3.7.2 APPLICAlllLITY and Associated liases.

1hc APPL 10AlllLITY of CTS 3.6.3 and ITS 3.6.3 is MODES 1,2,3, and 4.1he APPLICAlllLITY of CTS 3.7.1.$ is y MODES 1,2. and 3, lhe APPLICAlllLITY of STS 3.7.2 is MODE I and MODES 2 and 3 except when the ... valves are -!

closed and de activated. ITS 3.7.2 APPL.lCAlllLITY changes the STS APPLICAlllLITY to MODES 1,2 and 3. Contrary ,

to P.28 thit is not consistent with CTS 3.6.3 or ITS 3.6.3. Also, this doe snot address the importance of the phrase "except w hen ... dc activled" w hich means (Le valves are performing their 1*olation function w hen they are closed and hence the LCO does not apply.1his change la considered to be a generic change and is a beyond scope of review item for this ,

conversion. See item No. 3.7.3 5. Comment: Delete this generic change. '

ComFd Response to luue Consistent with the Comed Response to RAI 3.6.3 01. TSTF 44 9 9 he withdrawn from the ITS submittal. Comed is deleting LCO 3.7.3, "FW lsolation Valves," from the ITS submittal and retaining the requirements for feedwater vah es in 11S LCO 3.6.3,

• Containment isolation Valves," consistent with Ilyron/intaidwood Current Licensing liasis, in addition, LCO JFD 3.7 P28 will be resised to read

• Consistent with CTS LCO 3.7.l.5, the Applicability ofITS LCO 3.7.2 is revised to MODES 1,2, and 3, with no provisions for exclusion if all the valves are closed." This change will be provided in our

+

comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

NRC RAI Number NRC lisued Date RAI Status I 3.7.2 05 12/$/97 Open . NRC Action Required NRCla scription of luue 3.7.2 $ JFD Ilases C 4 ITS 113.7.211ases Cement: See item Number 3.6.3 1  !

Comed Response to issue Comed will develop a 'P' 11ases JFD for the justification of adding the paragraph to the 11ackground Section of the liases for LCO 3.7.1. This is stW a ive statement even with TSTF 44 withdrawn, in addition,11ases JFD C4 will be deleted. This change will be provided b our erinUchensive ITS Section 3.7 closeout submittal revision upon NRC's concurrence with I the Comed Responses '.o the 1TS Section 3.7 RAI.

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Respo:se to NRC ital D;ted 12/05/97 os-r:b 9s

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NRC RAI Number NRC lisued Date RAIStatus i

( 3.7.2-06 12/5/97 Open NRC Action Required G] NRC Description of issue 3.7.26 S1 s 113.6.2 liases . SR 3.7.2.1 11S 113.7.2 liases SR 3.7.2.1 S1S 113.7.2 liases . SR 3.7.2.1 states the following in the last paragraph: "The test is conducted in MODE 3 with the unit at operating temperature and pressure as discussed in Reference 5 esercising requirements." ITS 113.7.2 liases SR 3.7.2.1 deletes the last part of this sentence "as discussed , requirements.* Nojustification is provided for this deletion.

Comment: Provide a discussion andjustification for this deletion based on current licensing basis, system design, or operational constraints.

Comed Response to issue Comed will conform to the S15.1his change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence uith the Comed Responses to the 11S Section 3.7 RAl.

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- . - _ .NRC RAI Number NRC issued Itate . RAI Status  !

3.7.3 01 12/$/97 Open.NRC Aetion Required NRC Descript6cn ofluue -

3.7.31 DOC A.$

DOC A.37 -

DOC A.38 l DOC A.39 -i DOC A.41 DOC A.47 i IX)C M.11-  !

DOC LA.34 ,

DOC LA.35 DOC LA.37 DOC L.25 DOC L.26 -*

JFD C.6 JFD P.6 JFD P.20 >

JI D P.27 JFD P.28 JFD Bases C.4 JFD liases C.7 JFD llases P.6 JFD liases P.7 JFD liases P.36 JFD Bases P.48 l

' r CTS 3/4.6.1.1 CT S 3/4.6.3 STS 3.7.3 and Associated liases 113 3.6.3  :

ITS 3.7.3 and Associated Bases i 4

_ CTS 3/4.6.l.1 and 3/4.6.3 contain the requirements for all feedwater valves which perfonn a contairiment isolation L . function. 'these requirements have been retained in the ils in ITS 3.6.3 (See item Number 3.6.3 1). The CTS does not contain a feedwater isolation valve LCO that addresses the other safety function OPERABILITY requirements. (See STS Il3.7.3 liases). It is acceptable to add ITS 3.7.3 under the guidance of NUREG 1431, based on these other safety function

. OPERABILITY requirements, not the containment isolation function, even though some of the ACTIONS and SRs may be j the same as required by CTS 3/4.6.1.1, and 3/4.6.3, and 11S 3.6.3. In addition, this new LCO as described byjustifications A.$ and M.ll have been altered by rejected generic changes TSTF 44 (see item Numbers 3.6.3 1,3,7.12,3.7.2 5, and ,

3.7,4 3) and TSTF 102 (see item Number 3.7.2 1), as w cll as other changes which the staff considers to be generic.

Comment

Revise the CTS /ITS markup to delete the reference to and markups of CTS 3/4.6.1.1 and 3/4.6.3 and TSTF 44 i ' and 'lSTF 102. Refer to item Numbers 3.7.3 2,3.7.3 3,3.7.3 4, and 3.7.3 5 for additional comments that teflect changes to the CTS markup ofjustification M.II (CTS Insert 3.6.1 A). >

Comed Response to issue Consistent whh the Comed Response to RAI 3.6.3-01, TSTF 44 will be withdrawn from the ITS submittal. Comed is deleting 1.CO 3.7.3, *FW Isolation Valves," from the ITS submittal and retaining the requirements for feedwater valves in -!

l 1 TS LCO 3.6.3, " Containment Isolation Valves," consistent with Byroa/Ilraidwood Current Licensing Basis. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (See RAI 3.7.3 02.)

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== 1 Response to NRC RAI D:ted . 12/05/97 05 reb 9s t

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Nii6R iNumber NR61 SItil Date RSI Status 3.7.3-02 12/$/97 Open . NRC Action Required

[

HNC Descriptkm of issue 3.7.32 DOC M.I1 -

DGC L23 JFD P.6 JFD liases P.7 r STS SR 3.7.3.1. '

11S SR 3.7.3.1 [

Ils SR 3.7.3.2 and Associated liases 1 1he ITS markup breaks STS SR 3.7.3.1 into two SRs . ITS SR 3.7.3.1 (verification of closure in speelned time limit) and ITS SR 3.7.2.2 (verincation of closure by actual or simulated signal). The justlucation for this change (P.6) is that if the valve fails the closure time SR, there is no need to perform a full actuation test (ITS SR 3.7.3.2) since closure time can be  !

4 measured without this test.1his change is considered to be a generic change w hich is beyond the scope of review for this conversion. See item Number 3.7.2 3. Comment: Delete this generic change.

Comed Response to issue  !

See Comed Response to RAI 3.7.3 01.

t --

NHC RAI Number NRC lasued Date RAI Status ,

3.7.3 03 12/$/97 Open . NRC Action Required

NRC Description of lasue 3.7.3 3 IX)C M.II JFD P.6 i

g JFD P20 JFD liases P.36 STS SR 3.7.3.1 and Associated liases ITS SR 3.7.3.1 and Associated Ilases STS SR 3.7.3.1 and its Associated !!ases specifies the closure time of [7] seconds for each main feedwater isolation valve.

. Justilisation P.6 separates STS 3.7.3.1 into two SRs (see item 3.7.3 2). Justification P.20 and !!ases P.36 relocates the

, closure time for the FW isolation valves to the TRM. While the staff finds the modi 0 cation made by ITS SR 3.7.3.1 of STS SR 3.7.3.1 in w hich the specinc closure time is changed to "within limits" due to the number of valves involved and the different closure times, we do not Ond the relocation of the times to the TRM as acceptable. The times should be listed in the ITS 113.7.3 liases . SR 3.7.3.1 as is specined in the STS and to be consistent with other multi limit components in other LCOs.' in addition the stati Ands that the relocation of the closure times to the TRM and associated changes to the Bases (llases P.36) to be generic. Comment: Revise ITS 113.7.3 !!ases . SR 3.7.3.1 to include the closure times for each FW isolation valve.

Comed Response to issue

. See Comed Response to RAI 3.7.3 01, i

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Response b NRC RAI Dated 12/05/97 os reb-9s "NRC MAI Number NRC lssued Date RAI Status 3.7.3 04 12/3/97 Open . NRC Action Required l . NRC Ikseription oflisue 3.73 4 DOC M.11 i JfD P.27 l JFD flases P.48 STS 3.7.3 ACTIONS Note 11S 3.7.3 ACTIONS Note 2 and Associated llases 11S 3.7.3 adds the following Note to the ACTIONS scetion: "2. Flow path (s) may be unisolated intermittently under

- administrative controls." While this statement is acceptable in STS/ITS 3.6.3, it has not been approved for STS 3.7.3, not according to CTS 4.6.l.la and CTS Tab!c 3.61 have the FW isolation valves been granted this exception. Thus the staff .

considers this change to be generic and beyond the scope of review for this conversion. Comment: Delete this generic

'. change.

Comed Response to issue See Comed Response to RAI 3.7.3 01.

t i NRC RAI Number NRC Issued Date RAI Status 3.7.3 05 12/5/97 Open. NRC Action Required NRC Description ofissue 3.7.33 DOC M.1l JFD P.28 JrD liases P.6 CTS 3/4.63

'O ITS 3.6.3 APPLICAlllLITY STS 3.7.3 APPLICAlllLITY '

ITS 3.7.3 APPLICAlllLITY and Associated llases The APPLICABILITY of CTS 3.6.3 and ITS 3.6.3 is MODES 1,2,3, and 4. The APPLICAlllLITY of STS 3.7.3 is MODES -

1,2, and 3 except when ... is closed and [de-activated)[or isolated by a closed manual valve]. ITS 3.7.3 APPLICAlllLITY changes the STS APPL.lCABILITY to MODES 1. 2 and 3. Contrary to P.28 this is not consistent with CTS 3.6.3 or ITS 3.6.3 Also this does not address the importance of the phrase 'except when .., valve." which means the valves are

- performing their isolation function when they are closed and hence the LCO does to apply. 7 his change is considered to be  ;

a generic change and is a beyond the scope review item for this conversion. See item Number 3.7.2 4. Comment: Delete -

this generic change.

Comed Response to issue See Comed Response to RAI 3,7.3 01.

k b f .

b -

__ Response to NRC RAI Dated 12/05/97_ Os reb 9s RAl5taiuI

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~5R6N5ISu~mber SliC 165d Naie-3.7.3-06 12/5/97- Open . NRC Action Required NRC l>escription of issue 3.7.36 JFD Ilases P.36

' S1S 113.7.3 liases . LCO 115113.7.311ases . LCO S15113.7.3 Ilases . LCO the last sentences in the first paragraph states the following: "1hese valves will also isolate the non safety related portions from the safety related portions of the system." lls fl 3,7.3 liases . LCO deletes this sentence.

No justification is provided escept for the generaljustification (llanen P.36) on system design.1his is an inadequate

- justl0 cation for the change. The deletion of this statement ;mplies that all of the main feedwater system is safety related.

Comment: Provide additional discussion and justification for this deletion based on current lleensing basis, system design, or operational constraints.

Comed Response to issue See Comed Response to RAI 3.7.3 01.

l

=._. -.

=

NRC RAI Number NRC lisued l> ate RAI Status 3.7.3 07 12/5/97 Open.NRC Action Required NRC Description ofissue 3.7.37 JfD Ilase P.36 STS 113.7.3 liases . SR 3.7.3.1 and REFERENCES ITS 113.7.3 liases . SR 3.7.3.1 and REFERENCES STS 113.7.3 liases . SR 3.7.3.. states the following in the first paragraph: "These valves should not be tested at pow er . ..

( ASME Code,Section XI (Ref.2) ... operation in MODES I and 2 " ITS 13 3.7.3 Ilases . SR 3.7.3,1 deletes these sentences and Reference 2 from the REFERENCE Section. Nojustincation is provided except for the generaljustincation (Base P.36) on system design. This is an inadequatejustincation for this change. Comment: Provide additional discussion and justi0 cation for this deletion based on current licensing basis, system design, o,' operational constraints.

Comed Response to Issue See Comed Response to RAI 3.7.3 01

- . - - = = =

0 MN o

==- _ - _ -

Response to NRC RAI Dated 12/05/97 05-reh-9s

'idFRXiNEber NEFISIwefDate RAlStaius

~

3.7.40l 12/$/97 Open.NRC Action Required NRC Descript6on of luue 3.7.4.1 DOC M.II JFD il.19 jf D P.2 Ji D liases P.2 Il D liases 11.l$ :

S1S 3.7.4 APPLICAlllLITY STS 3.7.4 RA C.2 and Associated Completion Time ITS 3.7.4 APPLICAlllLITY and Associated liases ITS 3.7.4 RA C.2, Associated Comp!ction Time and Associated liases

. STS 3.7.4 APPLICAlllLITY and the APPLICAlllLITY of a number of other 3.7 STS require the 50 PORVs to be l

OPERAllLE in " MODE 4 when the steam generator is telled upon for heat removal." STS 3.7.4 RA C.2 requires if the Required Action and Associated Completion Times are not met, the plant must lle in MODE 4 without reliance upon steam generator for heat removal" in a Completion Time of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. - The other 3.7 STS either have similar ACTIONS or different AC110NS as well as additional notes to LCOs and SRs which relate to the system's OPERAlllLITY in MODE 4 when the steam generator is relied upon for heat removal. ITS 3.7.4 and the other 3.7 STS have been modined to delete this OPERAlllLITY requirement and change the associated ACTIONS, Completion Times and Notes. These changes in ITS 3.7.4 are designated as 11.19, P.2, liases P.2 and llases 11.14 (see item Numbers 3.7.$ 3 and 3.7.61 for applicable DOCS and JFDs). This proposed change was submitted to the staff in TSTF 29 and rejected, based on the fact that the change over from Auxiliary Feedwater (AP) System to Residual llent Removal (RllR) System does not take place exactly at the MODE 3 to MODE 4 change over but at some time into MODE 4, as well as the fact that the AF System is also used for startup in I MODE 4. Comment: Delete this change.

O Comed Response to issue No change Comed disagrees. The proposed changes discussed by the reviewer are not as a result of TSTF.29 although many of the Comed changes are also addressed in the subject TSTF The changes made by Comed are current licensing basis changes and reflect the design and operation of our plant. The proceduralized point for RilR initiation and the design of the RilR System is such that RilR is placed in shutdown cooling at the MODE 3/ MODE 4 transition point. Comed continues to pursue these changes on a plant specific basis. (See RAI 3.7.$-03 and RAI 3.7.6 01.) (Correction Note:

Auxiliary Feedwater is not used for startup sit flyron and tiraidwood Stations.)

==

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17-

=

R:sponse to NRC RAI Dat:d 12/05/97 os reb-9s

~

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~NNifNXI Number NNdinEeIt'l) ate RAl' Status 3.7.4 02- 12/$/97 Opcn . NRC Action Required NHC Description oflesue 3.7.42 DOC M.11 JFD P.24 JFD Bases P.44 T1S 3.7.4 RA A.I completion Time ITS 3.7.4 RA A.1 Completion Time .

With one SG PORY line inoperable ITS 3.7.4 RA A.1 Completion Time has been extended from the STS specined 7 days to 30 days, %s basis is that it has taken longe than 7 days in the past to restore a 50 PORY line to OPERAllLE status.

His is an inadequste justification because the issue not addressed should be re establishing in a timely manner the safety assumption for an SOTR event. In addition no infermation is provided to show that the 50 PORVs at Byron /Braidwood are l

_ any different than the PORVs/ADVs at other plants that would require this 4 fold increase in the Completion Time.

l Comment: Delete this chsnge or provide additional dicusuon and technicaljustl0 cation to show that the valves are

! sufliciently different from tbc PORVa/ADVs at other plants.

Comed Response to issue Comed disagrees. NUREO LCO 3.7,4 Required Action A.I Cempletion Time was changed from 30 days to 7 days. The 30 days was based on past history to perform maintanence and Environmental Qualification overhauls on the S0 PORVs.

In addition, Comed has performed a plant specific PRA which was approved by NRC letter dated October 27,1997.

Contained in the PRA was an evaluation of the SG PORVs being out of service for 30 days uhich was documented in Probabilistic Safety Assessment (PSA) sensitivity calculation llWR 97 0938. The risk associated with having the 50 PORV out-of service for 30 days every 2 years was 1.14E 05, his value shows that there is no signl0 cant difference in the probability or severity of core damage that would result during an accident. This 30 days out-of-service time has also been incorporated into the Comed Maintenance Rule Program. Here are only four (4) plants that have similar actuators as the O liraidwood' Byron BW/IP, Elector.llydraulic Operator. The four plants are Beaver Valley, Nine Mile, River Bend, and Vogtle. Of the four plants, only Beaver Valley & Nine Mile have these actuators installed in similar applications. Beaver Valley & Nine Mile have seen the same performance problems as Braidwood & Byron. River Bend and Vogtle have the actuator installed in continuously modulating applications. Comed continues to pursue this change.

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1

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

llespo:se to NitC llAl D:,ted 12/05/97 os reb 98

.=. = :: = = = =::--- == = := = =: - = = . = . l NRC RAI Number NRC issued Date itAlStatus i f 3.7.4-03 12/5/97 Open NRC Action Required NRC Description of issue 3.7.43 Ji~D C.4 11S 113.7.4 Ilases IIACKGROUND AND APPLICAllLE SAI ETY ANALYSES II'S 113.7.4 liases add words to the ilACKGROUND and APPLICAllLE SAFETY ANALYSI.S section that states that the SG PORVs are containment isolation valves (C!V) and the CIV function is addressed 11S 3.6.3 " Containment isolation Valves " While the statements are true the justification (C.4) used to add the statements is unacceptable. C.4 refers to TSTI-44, Rev.1,1S11%44 Rev. 0 has been rejected by the staff and TSTF 44 Rev. I has not been subt. titled for stalT approval. This change is considered a beyond scope of review item for this conversion. See item Number 3 6.31.

Comment: Delete this generic change.

Comed Response to issue No change. Comed disagrees that the paragraphs added to the Hackground and Applicable Safety Analysis Sections of the Ilases for LCO 3.7.4 are beyond scope. The CIV function of the SG PORVs is addressed by I.CO 3.6.3 in both CTS and ils. One of the several changen 1STT 44 proposed, provided additional information in liases 11.3.7.4. The specinc statements Comed added w ere, "The SG PORVs also serve as Containment isolation Valves (CIVs); however, the ClV function is addressed in LCO 3.6.3, " Containment isolation Yah es"," and "1he SG PORVs are also credited as CIVs (refer to LCO 3.6.3)." These statements are being maintained in the Bases since they do not change any technical information or intent as provided by NUREG 1431. The changes do not alter any Required Actions, Completion Times, or Surveillance Testing I requencies. The only intent is to provide a more accurate description of both the llyron and tiraidwood plant designs and to better assist the operators in locating associated LCOs. Although originally part of TSTF 44, the human factors benent and enhancement obtained from these changesjustifies them being pursued on a plant specific basis. liases JFD 3.7 C4 will be deleted and a 'P'Ilases JFD errated tojustify these changes. Comed continues to pursue this change.

(See RAI 3.7.102.)

[ \

NRC ltAl Number NRC lssued Date RAl Status 3.7.5 01 12/5/97 Open NRC Action Required NRC Description of issue 3.7.5 1 DOC A.29 JFD P.14 JFD llases P,40 CTS 4.7.1.2.2 S1S SR 3.7.5.5 ITS SR 3.7.5.5 and Associated llases CTS 4.7.1.2.2 requites "an auxiliary feedwater now path to each steam generator shall N demonstrated OPERAllLE following each COLD SilUTDOWN., " STS SR 3.7.5.5 requires this SR be perfonned wheneser the unit has been in hiODE 5 or h10DE 6 for greater than 30 days. ITS SR 3.7.5.5 adds "or defueled for a cumulative period of" to the STS SR Frequency. This is a generic change which is a beyond scope of review item for this conversion. Comment: Delete this generic change.

Comed Response to issue No change. Hyron'llraidwood Stations presented this generic change to the Westinghouse Owncr's Group. The traveler is under TSTF consideration as WOO 96. The STS does not provide any specine guidance w hen the unit is in an undenned condition such as "defueled." Adding the phrase,"w henever unit has been in h10DE 5, h10DE 6, or defueled for a cumulative period of greater than 30 days," clarines uhen the SR is applicable. ComCd continues to pursue this change on a plant specine basis, J

19

Respo:se b NRC RAI Dated 12/05/97 05 reb 9s -

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NHC MAI Number NMC 16 sued Date - RAI Status 3.7.$ 02 ' 12/$/97 Open NRC Action Required NRC Description of lasue 3.7.52 DOC 1.A.4 CTS 3.7.l.2.b CTS 4.7.l.2.3 CTS 3.7.1.2.b specines the minimum diesel day tank volume of the diesel driven AF system pump and CTS 4.7.1.2.3 specines the SR needed to be performed and the frequency to demonstrate that the AF system diesel driven pump is OPERAllLE. Thejustl0 cation (LA.4) states that these OpERAlllLl1Y requirements are to be relocated to the TRM. The stalT finds this unacceptable. The discussion and justification used w ould also allow the OpERAlllLi1Y requirements for the Emergency Diesel Generator (E!X)) Fuel Oil System in ITS 3.8 to be relocated to the TRM. The stafifinds that C1S 4.7.1.2.3.c may be relocated to the TRM, based on the justifications in the staff Safety Evaluation issued with Amendments 71 for Ilraidwood and 79 for flyron dated 2/16/97 w hlch relocated the similar EDO requirement (CTS 4.8.1.1.2.f.1)). !!ased on Sis /ITS 3.8, CTS 3.7.1.2.b (day tank volume only) and CT S 4.7.1,2.3.a needs to be retained as SRs in ITS 3.7.$. In

- addition the fuel oil testing for CTS 4.7.l.2.3.b needs to be retained as an SR in ITS 3.7.5, however the details of the testing (ASTM Standards) may be relocated to ITS $.$.13. Comment: Revise the CTS and ITS submittals accordingly and progide any additional discussion andjustl0 cation to suppon these changes.

Comed Mesponse to luue No change. Comed disagrees that CTS 3.7.1.2.b and 4.7.1.2.3 need to be incorporated into the ITS. 'the information contained in these two CTS subparts require that in order for the auxiliary feedwater pump diesel to be demonstrated OPERAllLE, the diesel day tank shall maintain a volume of 420 gallons of diesel fuel oil. This is to be veri 0ed every 31 days. In addition, every 18 months the diesel shall be inspected in accordance with the manufacturer's recommendations, The NRC reviewer states that the staff finds relocating these requirements to the TRM is unacceptable and they are needed to demonstrate OPERAlllLi1Y of the diesel pump. Essentially all CTS SRs make a generic introductory statement that a specluc component or piece of equipment shall be demonstrated OPERAllLE by the successful performance of a specine O. SR. Almost all of the CTS SRs relocated to the TRM contain the cuct same statement of demonstrating OpEllAlllLITY through the performance of the SR.1he difference between retalning specinc requirements in the ITS or relocating them to a licensee controlled document (i.e., TRM) is if the requirement meets the NRC criteria as stated in 10CFR$0.36(cX2)(ll).

In this specific case, the requirements being rstocated do not meet the NRC acceptance criteria as stated in 10CI R$0.36(cX2Xil). Relocating the subject SRs to a licensee controlled document does not climinate these requirements, does not change frequency of verifying the diesel fuel oil volume, nor eliminate any inspections being performed in accordance with the manufacturer's recommendations. Comed feels that these requirements are still enential and

' relocating them to a licensee controlled document does not in any way lessen their imponance Once these requirements are maintained in a licensee controlled document any changes would be subject to a 10CFR$0.59 cvaluation, in addition, all the STS 3.7.5 SRs as stated in NUREO 1431, are maintained in the ITS with minor changes made to accommodate plant design and current licensing basis. These SRs have been identified by the NRC and industry as adequate to demonstrate

- OPERAlllLilY from a STS point of view, liased on the fact that the subject requirements are maintained in a licensee controlled document as required by he NRC 10CFR$0.36(cX2Xii) the ITS will not be revised to incorporate these requirements. Comed continues to pursue this change.

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~.,nw--_..._._nn Response to NRC RAI D:ted 12/05/97 Os reb-9s NRC RAI Number NRC lssued Date RAIStatus 3.7.$ 03 12/$/97 Open. NRC Action Required NRC Description of issue 3.7.$3 DOC L.2 JFD P.2 JFD liases 11.2 JFD liasesP.2 JFD liases P.8 CTS 3.7.1.2 ACTION b.

115 LCO 3.7.5 Note ITS 3.7.$ APPLICAlllLITY 115 3.7.$ ACTIONS ITS SR 3.7.$.3 Note iIS SR 3.7.5.4 Note and Associate liases Comment: See llem Number 3.7.4 1.

Comed Response to issue Reference Comed response to RAI 3.7.4 01.

NRC RAI Number NRC lisued Dete RAI Status 3.7.5-04 12/$/97 Open NRC Action Required NRC Description of issue 3.7.$-4 JFD 11.6 JFD C,1 O ITS 3.7.$ Condition 11 ITS 3.7.5 Condition 11 contains a C.1 change identifier; however, the, justifications listing states that C.I was not used. This appears to be an error since !! 6 deletes this portion of the Condition statement. Comment: Revise the submittal to correct this discrepancy.

Comed Response to lisi.e Comed will delete the 'Cl' designator in Condition 11 of LCO 3.7.5. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAI.

' NRC RAI Number NRC lasued Date RAI Status 37.6-01 12/$/97 Open.NRC Action Required NRC Description of lasce 3.7,61 JFD 11.2 JFD P.2 JFD liases 11.2 JFD Ilases P.2 ITS 3.7.6 APPLICAlllLITY ITS 3.7.6 RA 11.2 and Assoc 4(ed tiraes Comment: See item 3.7.4 I Comed Response to issue See Comed resp (mse to RAI 3.7.4 01.

R:sponse to NRC RAI Dated 12/05/97 os. reb.9s i

~NRC EXI'NAIE~5RC inwelitale ~ ~ N 5titatus

~

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3.7.6 02 12/5/97 Open. NRC Action Required NRC llescripilon of issue 1

3.7.62 JFD liases P.1

• STS 11.37.6 liases. APPLICAllLE sal'ETY ANALYSES l ITS 113.7.6 !!ases APPLICAllLE SAFE 1Y ANALYSES I 11S 113.7.6 liases . APPLICAllLE SAFETY ANALYSES deletes from the third paragraph, second sentence of STS 113.7.6 '

the following words: "since the Emergency feedwater Actuation System would not detect a difference in pressure between the steam generators for this break location." 'this deletion in justified as an editorial change w hen it is a technical change. i Nojustification povided for this change. Comment: Provide additional discussion and justification to explain this deletion '

or adopt the STS teat.

Comed Response to lasue ,

Comed will provide additionaljustification for deleting the statement, since Emergency feedwater Actuation System would not detect a difference in pressure beta een the steam generators for this break location. 'this justification w ill be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Respenses to the ITS Section 3.7 RAl.

=n-~ _ i NRC RAI Number NRC lasued I)nte RAI Status 3.7.6-03 12/$/97 Open NRC Action Required #

NRC I)escription oflasue 3.7.6 3 JFD liases P8 STS 113.7.6 Ilase LCO ITS 113.7.6 liases L(/J ITS 113.7.6 Ilases LCO deletes from STS 113.7.6 the entire $ccond paragraph. Ilowever, the last sentence in this paragraph w hich states: "1his basis is established in Reference 4 and exceeds the volume required by the accident analysis" appears to ji be applicable. Comment: Revise the submittal to adopt the STS wording, or provi& additional discussion orjustification to support its deletion.

Comed Resp <mse to issue No change. Comed disagrees, Reference 4 was deleted from the ITS submittal since there is no Reference 4 listed in the NUREG References Section of the liases for LCO 3.7.6. The proposed insert !! 3.7 33 A reflects both the llraidwood and Ilyron designs. Without being able to verify w hat the reference is or the analysis it uses, Comed cannot make the generic

. statement in the NUREG llases, and exceeds the volume required by the accident analysis. Comed continues to pursue this

' change.

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Response to NitC ltAl Dated 12/05/97 Os nb-n

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NRC RAI Number NRC lisued Date i Al Status

() 3.7.7-01 12/5'97 Open NRC Action Required NRC Description of lisue 3.7.71 DOC A.12 DOC M.4 DOC l.A.6 Ji D P.I JI D P.7 Ji D P.2$

JI D llaws P.15 CTS 3.7.3 CIS 3.7.3 ACTIONS STS 3.77 ACTIONS 1iS LCO 3.7.7 l'lS 3.7.7 ACTIONS and Associatd liases l

ITS 113.7.7 Ilases . IIACKGROUND states that the CC System is a shared sptem consisting of Ove pumps (four unit-l Spectue and one common), three heat exchangers (two unit specinc and one common), and two unit-specific surge tanks.

l There i.re no indications in the C1S or ITS associated llases that this system is shared between the units and no indication of inter unit dependence in the CTS For example when the common heat exchanger is inoperable and regardless of which MODl! cach unit may be in, both units must simultaneously enter the appropriate ACTIONS. The STS did not consider

! shared unit operation of a sptem. ITS LCO 3.7.7 and its associated liases seems to address shared system OPERAlllLITY, l how~ ct, ilS 3.7.7 ACTIONS still are based on a per unit basis with no indication of the various system alignments or of inter unit dependence, liased on the staffs review of the information submitted and the i SAR we believe that CTS 3.7.3 -

ACTIONS and the proposed ITS 3.7.7. ACTIONS do not seem to cover all potential system conngurations, unit operational

- MODliS and inoperabilities. Comment: In order to fully understand the system and the proposed ITS, provide a complete (m)

'V listing of all possible system con 0gurations. The listing for the plant (both units)is to include the following for each con 0guration.

a. 'lhe pumps, heat exchangers and loops required to be OPERAIlLE.

b. The operating MODE for each unit (both operating and one unit operating with the other unit shutdown.

c. The ACTIONS to be taken uith one or more components inoperable.

Revise ITS 3.7.7 ACTIONS based on the results of the above listing and unit inter dependence. The items that may have to be considered in the revised ACTIONS are loss of function (LCO 3.0.3 entry), entering more than one ACTION currently (STS 1.3 Example lJ 3 and correct placement of Notes. Note: A Note such as that proposed for ITS 3.7.10,ITS 3.7.11, and 11 S 3.7,12 (see item Numbers 3.7.101,3.7.11 1 and 3.7.12 1 respectively) may not be adequate to resolve this concem. Provide any additional discussions andjustifications as appropriate.

Comed Response to issue No change. Comed disagrees that "there are no indications in ITS Ilases that this system is shared between the units." The Grst sentence in the ITS Ilases for LCO 3.7.7 states, "The CC System is a shared system w hich . . ", the first sentence in Insert 113.7 36A states, "'lhe shared CC system consists of... ", among ses eral other places in the ITS Ilases. The pumps, heat exchangers, and loops required to be operable are delineated in Insert 113.7 37A in the I.CO Section of the liases. The operating mode for each unit is specined in the LCO Applicability, and pertains to each unit individually and independently, The actions to be taken w ith one or more components inoperable are delineated in the Required Actions for the corresponding Conditions. Again, the Conditions apply to each unit individually and independently. Comed does not believe that any changes need to be made to the ITS LCO or flues. l'ach affected unit would independently enter the applicable LCO for this shared system LCOjust like each unit would independently enter the applicable LCO for non-shared system LCOs. Comed continues to pursue this change.

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Response to NRC RAI Dat:d 12/05/97 05. reb 9s

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NRC RAI Number NRC lasued llate RAI Status 3.7.7 02 12/$/97 open . NRC Action Required NRC Description ofissue 3.7.72 DOC A 40 JrD P.17 JfD liases P.1$

CIS 4.7.3.3.b ITS SR 3.7.7.2 and Associated liases CTS 4.7.3.3.b requires verifying that the Essential Service Water (SX) system is available to each CC llent Exchanger. The 11S adds this tequirement at 11S SR 3.7.7.2 and rnodines it to verify correct SX splem valve position. ITS 113.7.7 liases .

SR 3.7.7.2 states that the SR verines that the valves are in the correct position or can be aligned to the correct position, in light of the SX system $ crying a shared system as well as being a shared system with regards to CTS 3.7.4.1, the Bases for SR 3.7.7.2 should be modined to describe w hat is meant by" can be aligned to the correct position" with regard to the shared portions of the CC and SX Sptems. Comment: Revise the Bases for SR 3.7.7.2 accordingly, and provide any additional dircussion and justincation as necessary.

Comed Rcoponse to issue -

No change. Comed disagrees. The structure and wording of the SR Bases is consistent with other statements concerning valve alignments in other liases. Comed has procedures that identify the correct valve position of each associated valve for a specific plant / valve alignment. With plant procedures maintaining this level of detall, Comed does not believe that the liases also need to maintain this level of detail. For consistency, the entire ITS !!ases would require review and revision to add this level of detail for similar SRs. Comed continues to pursue this cbnge.

NRC RAI Number NRC issued innte RAI Status 3.7.7 03 12/$/97 Open Comed Action Required NRC lleseription oflasue 3.7.73 - DOC M.4 JrD P.25 CTS 3.7.3 ACTIONS. Insed 3.7.ll A STS 3.7.7 RA A.I Note ITS 3.7.7 ACTIONS Note Justi0 cation M.4 states that a Note is added to CTS 3.7.3 ACTIONS consistent with NUREO.1431 STS 3.7.7 RA A.I Note.

The Note requires that the applicable Required Actions be entered if the residuallient Removal (RHR) System is made inoperable by the inoperable CC system. While the addition of this type of Note is acceptable, M.4 states that this change represents an additional restriction on plant operation. The staff disagrees. The Note does not represent n additional restriction on plant operation. Since the CTS requires cascading with regards to inoperable suppon systems (CC system is a support system to the RilR system), the NOTE represents current requirements and therefore is an Administrative change.

See item Numbers 3.7.71 for Note location and 3.7.7 4 for concerns on Note wording); Comment: provide additional discussion andjustincation for this Administrative change.

Comed Response to issue -

No change.' Comed disagrees. Due to the alignment of Allowed Outage Times within the CTS, cascading for single train H

7erabilities is not necessary and only creates an administrative burden without a compensating increase in safety. For 1dundant train inoperabilities, the cumulative effect is considered and LCOs are entered commensurate with the level of degradation experienced. Situations w hich result in a loss of safety function absent a single failure are not permitted.

Comed continues to pursue this change. (See RAI 3.7.8 05 and RAI 3.7.13 04.)

N DE44$.. 'N 24 4

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Response to NRC RAI Dateil2/05/97 os rch-9s NRC M AI Number NRC lasued Date RAI Status 3.7.7-04 12/5/97 Open NRC Action Required NRC Description ofissue 3.7.74 DOC M.4

.JFD P.25 C1S 3.7.3 ACTIONS Insert 3.7 ll A i STS 3.7.7 RA A.1 Note l ITS 3.7.7 ACTIONS Note STS 3.7.7 RA A.I Note states the following: *Ent(r applicable Conditions and Required Actions of LCO 3.4.6,'P.CS Loops MODE 4', for residual heat removalloops made inoperable by CCW." ITS 3.7.7 moves the Note from RA A.I to under ACTIONS (See item Number 3.7.71 for concern on location) and changes the wonding from " loops made inoperable" to

• loops if made inoperable..." The staff unds this change to be generic and beyond the scope of review for this conversion. See item Number 3.7.8 3. Comment: Delete this generic change.

Comed Response to issue The relocation of the Note is neither a generic not beyond scope change, but rather a plant speel0c change based on the liyron/Draldwood CC system design. The CC system is a shared system that employs two CC pumps per unit, one common CC pump, one CC heat exchanger per unit, and one common heat exchanger. The NUREO was developed based on a stand-alone two train CC system.1he proposed change reDects current design which resulted in NUREG Condition A being split into two separate conditions (i.e., Conditions A and 11)in ITS. Ilowever, the Note was revised to adopt the STS wording.

1his change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (See RAI 3.6.2 02 and RAI 3.7.8-06.)

- := = = = = 2 .-

NRC R AI Number NRC lasued Date RAI Status p 3.7.7 05 12/5/97 Open NRC Action Required NRC Description oflasue 3.7.75 Ji'D P.7 CTS 4.7.3.2.b STS SR 3.7.7.3 ITS SR 3.7.73 and Associated liases CTS 4.7.3.2.b requires verifying that each CC pump starts automatically on a Si test signal at least once per 18 months.

' STS SR 3.7.7,3 performs the same surveillance on each pump. ITS SR 3.7.7.3 changes the STS wording from "cach CC

. pump" to " required CC pump." This change is not in accordance with the CTS requirements of each pump and no justi0 cations is provided. In addition this change would allow one of the Ove CC pumps to be inoperable indennitely. This is unacceptable to the staff. Comment: Revise ITS SR 3.7.7.3 to conform to CTS 4.7.3.2.b with regards to testing of all the

. CC pumps.

Comed Response to lasue No change. Comed disagrees. CTS 4.7.3.2 states,"At least two component cooling water pumps shall be demonstrated OPLRAllLE by performing the following: Verifying . . that each component cooling water pump starts ... on a Si test signal." Therefore, by each unit testing its associated unit specific CC pumps the CTS SP. is satisned. - Although not good operating practice, the common CC pump would not be required to be tested per CTS. Therefore, the addition of the word

• required" in ITS SR 3.7.7.3 is in accordance the CTS requirements. Additionally, the Staficommented that " , this change would allow one of the Ove CC pumps to be inoperable indennitely " Again, while not good operating practice, CTS LCO 3.7.3 docs not require a Of1h CC pump to be operable as long as each unit has two operable CC pumps. Comed continues to pursue this change.

4 R:spode to NRC RAI D:ted 12/05/97 Os-reb-9s

. _ . .~

, NRC RAI Number NRC l$ sued Date RAIStatus  !

3.7.7-06 12/$/97 Open . NRC Action Required .

NRC Description oilssue 4-3.7.7-6 JfD P.8 STS SR 3.7.7.2

] ITS SR 3.7.7.3 ITS SR 3.7.7.3 shows that c.ianges were made to this SR as a result of P.8. Just10 cation P.8 deals with the deletion of STS SR 3.7.7.2 and no changes are show in ITS SR 3.7.7.3 which relate to P.S. Comment: Correct this discrepancy.

Comed Response to issue ,

Comed agrees that LCO JFD 3.7 P8 is not applicable to 11S SR 3.7.7.3. The LCO markup for ITS SR 3.7.7.3 will be j' revised in our comprehensive ITS Section 3.7 closcout submittal tevision upon NRC's concurrence with the Comed >

Responses to the ITS Section 3.7 RAl.

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NRC RAI Number NRC issu *d Date RAI Status 3.7.8-01 12/5/97 Open.NRC Action Required $

NRC Description ofissue l

3.7.8 1 IX)C A.t4 DOC ht6 DOC LA 12 JFD P.9 JFD Ilases P.18 CTS 3.7.4.1 CTS 3.7.4.1 APPLICAlllLITY

• g ITS LCO 3.7.8.b and Associated Bases CTS 3.7,4.1 and ITS LCO 3.7.8.b require the opposite unit SX train to be OPERABLE for the unit speel0c suppot1 when the opposite unit is in MODES $ or 6 or defueled. With the opposite unit in MODE $ or 6, the SX system serves as a

- support system with no TS imposed requirements for opposite unit. Thus, its OPERAlllLITY is determined by the dc0nition of OPERAllLE and the system (s) it supports. It is unclear w hich opposite unit train is required to be OPERAllLE for the unit specinc support. For example, ITS 3.8.2 requires a Emergency Diesel Generator to be OPERA 11LE in MODES

- $ and 6. Ily the definition of OPERABLE-OPERAtllLITY, the associated SX train would be required to be OPERAllLE to ,

support EDO operations. Would this opposite unit SX train also be considered as the opposite unit SX train required to be >

OPERAllLE per ITS LCO 3.7.8.b for the unit specinc requirement or would the other opposite unit SX train be the one used. This may involve a reevaluation of the CTS /ITS APPLICA!11LITY (see item Number 3.7.8 2). Comment: Provide additional discussion and justincation for this concern. Revise the submittal as appropriate.

Comed Response to issue .

. No change. Since the SX trains are cross tied, it is not necessary nor desirable to specify in the LCO or Conditions which SX pump is the designated " opposite unit SX pump " Comed believes that through continuing operator training. approved plant procedures, and the requirements of CTS, the ITS LCO is not confusing and is understandable as written. Comed continues to pursue this change.

3

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Response to NRC RAI D:ted 12/05/97 Os reb 9s

)RC'NAl'NM ~NREfsIudlEtt IAStatus ~~

3.7.8-02 12/5/97 Open + NRC Action Required NRC Description of lisue 3.7.82 DOC.A.14 DOC LA.12 C1S3.7.4.1 CTS 3.7A.1 ACTION in CTS 3.7A.I ACTION, LA.12 indicates a change has been made to refer to the Essential Service Water pump as the *SX trains" in two places; w hereas the name change is justined in CTS 4.7.4.1 under A.14. A.14 is acceptable w hile LA.12 already applies to the relocation of CTS 3.7.4.1. Therefore, the CTS markup should be changed to be consistent.

Comment: Revise the C1S markup and provide additional discussion and technicaljustification for this Administrative change.

Comed Response to issue Comed agrees that in the CTS 3.7.4.1 markup, the 'LAl2' in the Actions should be changed to 'A 13', consistent with the change made to CTS SR 4.7.4.1.1his change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAI.

NRC RAI Number NRC lisued I) ate RAI Status 3.7.8 03 12/5/97 Open.NRC Action Required

' NRC lieseription ofissue 3,7.83 DOC A.15 DOC M.6 JI7D liases P.18 C: CTS 3.7A APPLICAlllLITY CTS 3.7.4.1 APPLICAlllLITY CTS 3.7.4.2 APPLICABILITY STS 3.7.8 APPLICAlllLITY Ils 3.7.8 APPLICABILITY and Associate Bases CTS 3.7.4 APPLICABILITY specifies that the unit-specine SX System shall be OPERAllLE in MODES 1,2,3, and 4.

CTS 3.7A.I includes an APPLICAlllLITY for the opposite unit SX system when the opposite unit is shut down to support the requirements for the specine unit. CTS 3.7.4.2 APPLICABILITY specifies that the unit cross tic shall be OPERAllLE when either unit is in MODES 1,2,3 or 4. These three CTS show an inter unit dependence as well as a sharing af the two units SX system. In converting from the CTS to the ITS the licensee used STS 3.7.8 APPLICAlllLITY, Thus,ITS 3.7.8 APPLICAlllLITY is only for MODES 1,2,3, and 4. The STS did not consider shared unit operation or inter unit

. dependence of a system. Thus, ITS 3.7.8 APPLICAlllLITY is not equivalent and could lead to confusion since the ITS is presented as a combined TS. Insert B.3.7 2C in ITS 113,7.8 Ilases . APPLICABILITY seems to describe the intent of the CTS. Thus, the following is proposed in order to make ITS 3.7.8 APPLICAlllLITY fit the situation, as claimed by M,6:

"APPLICAlllLITY: MODES 1,2,3 and 4 for the Unit Speci0c SX: and at all times for the Opposite unit SX train unit-

- specific support." The change to the nomenclature of" opposite-unit" and " specific-unit" is accepted. SX performs many functions but foremost is to support the RilR heat exchangers, in a GL 91 13 search for alternate SX water sources, it is reasonable that opposite-unit requirements would apply at power in order have another SX train available to achieve a COLD SilUTDOWN, when required. This is the object of the requirements in the new proposed APPLICABILITY. See item Number 3.7.8 1 for additional concerns in this area. Comment: Revise the CTS!!TS markup and provide additional discussion and technicaljusti0 cation for changes.

Comed Response to issue ITS LCO 3.7.8 Applicability will be modified to read, MODES 1,2,3, and 4 for the specific unit. This change will be O . provided in our comprehensive IT'S Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (Correction Note: Insert B 3.7 2C should be Insert il 3.7 42C.)

27

j R:sponse to NRC RAI D:ted 12/05/97 05 reb 98 i i

= = - = = = = = = = = = = = . = . = . = = = = . - - = = = . = = = = = = i

. NHC RAI Number NHC issued Date RAI Status  ;

3.7.8 04 12/$/97 Open NRC Action Required  !

NHC Description ofissue 3.7.84 DOC A.17 JFD P.9 .

a JFD liases P.18

, CTS 4.7.4.2.b l ils 3.7.8 and Associated liases i C15 4.7.4.2.b states that the provision of CTS 4.0.4 does not apply w hich allows entry into the specined MODE without C15 4.7.4.2.a having been petformed. ITS 3.7.8 does not contain this provision, bid A.17 states that " precise requirements  !

for performance of SRs are speclued in the ITS such that exceptions to SR 3.0.4 armot necessary " These requirements ,

, can not be located in 11S 3.7.8 and associated liases. Comment: Identify what then requirements are and w here they are located to verify thisjustincation. Provide additional discussion and technicaljusti0 cation for this Administrative change ,

as necessary. L Comed Response lo issue No change CTS SR 4,7.4.2 b states that the provision of CTS 4.0.4 does not apply. DOC 3.7.A l l states, "... The CTS has

been revised to delete this surveillance requirement provision since precise requirements for performance of SRs are 4

. Specined in the 11S such that exceptions to SR 3.0.4 are not necessary ... .* ITS LCO 3.7.8 applies to unit specific SX trains

and opposite unit SX trains. Funher,ITS SR 3.7.8.3 survells opposite-unit SX crosstie valves. Therefore, failure to meet SR 3.7.8.3 would constitute failure to meet LCO 3.7.8, and Condition B would be entered for an opposite unit SX train inoperable, llowever, since Condition B Note states *LCO 3.0.4 is not applicable," the unit can change modes w hile in

~ Condition 11. This translates into the unit being alle to change modes with SR 3.7.8.3 not met. Therefore, an exception to SR 3.0.4 is not necessary for SR 3.7.8.3. Comed continues to pursue this change, i NHC RAI Number NRC lasued Date RAI Status i 3.7.805 12/$/97 Open. Comed Action Required NRC Description of issue 3.7.85 DOC M.$

JFD P.25 CTS 3.7.4 ACTIONS insert 3.712 A STS 3.7.8 RA A.l Notes

- ITS 3.7.8 RA A.I Notes Justincation M.$ states that two Notes are added to CTS 3.7.4 ACTIONS consistent with NUREG 1431 STS 3.7.8 RA A.1 Notes. The Notes require that the applicable Required Actions be entered if the Residualllent Removal (RilR) Syvam and Emergency Diesel Generator (EDG) are made inoperable by the inoperable SX System. While the addition of the . Notes

- is acceptable, M.$ states that this change represents an additional restriction on plant operation. The stafTdisagrees. The Notes do not represent an addidonal restriction on plant operation. Since the CTS requires cascading with regards to inoperable suppon system (SX system is a support system to the RilR system and EDG) the Note represents current requirements and therefore is an Administrative change. See item Number 3.7.8-6 for concems on Note wording).

- Comment: Proivde additonal discussion andjusti0 cation for this Administrative change.

Comed Response to issue

No change. Comed disagrees. Due to the alignment of Allowed Outage Times within the CTS, cascading for single train inoperabilities is not necessary and only creates an administratise burden without a compensating increase in safety. For redundant train inoperabilities, the cumulative effect is considered and LCOs are entered commensurate with the level of.

degradation experienced. Situations uhich result in a loss of safety function absent a single failure are not permitted.

Comed continues to pursue this change. (See RAI 3.7.7 03 and RAI 3.7.13 04.)

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- - . . .R:sponse to NRC RAI Dated _ _ _ _ _ . . _ _ _ -12/05/97 05 reb-9s

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NRC RAI Number NRC lisutd Dats RAI Status 3.7.8 06 12/$/97 Open . NRC Action Required NRC Description oflisue 3.7.86 IX)C M.$

JFD P.25 CTS 3.7.3 ACTIONS Insert 1.7.12A S1S 3.7.8 RA A.1 Note ITS 3.7.8 RA A.I Note S1S 3.7.8 RA A.I Notes state the following: " Enter appliceble Conditions and Required Actions ...made inoperable by SWS ITS 3.7.8 changes the wording from *made inoperable" to "if made inoperable..." The staff finds this change to be generic and beyond the scope of review for this consersion. See item Number 3.7.7 $. Comment: Delete this generic change.

Comr,d Response to issue The Note was revised to adopt the STS wording. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision uptm NRC's concurrence whh the Comed Responses to the ITS Section 3.7 RAl (See RAI 3.6.2-02 and 3.7.7 09).

NRC R AI Number NRC lisued Date H AI Status 3.7.8 07 12/$/97 Open . NRC Action Required NRC Description ofissue 3.7.8 7 DOC M.6 C15 3.7.4 CTS 3.7.4.1 ACTIONS

' Justi0 cation M.6 states the following: *llS 3.7.8 Condition il allows a 7 day Compiction Time while CTS would allow a total of 7 days and 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />." This was based on CTS 3.7.4 ACTIONS (37 huers) and 3.7.4.1 ACTIONS (7 days). The basis for the statement is incorrect. CTS 3.0.3 not CTS 3.?.4 is the correct action to Reference. Comment: Correct this discrepancy in justincation M.6 Comed Response to Innue DOC 3.7 M6 will be revised to state,"... If for example, Unit I and Unit 2 weie operating and both Unit 1 pumps became inoperable, CTS 3.7.4.1 would not be applicable to Unit 2 until Unit I had shutdown in accordance with 3.0.3 Actions (37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />) and then Unit 2 would have 7 days from the time Unit I reached Mode $ . . ." This change will be provided in our comprehensive ITS Scction 3.7 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAI, O

29

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ltsponse to NitC llAl D:ted 12/05/97 Os r:b 9s NRC R AI Numbec NRC issued Date RAI Status (O 3.7.8-08 12/5'97 Open.NRC Action Required

') NRC Det.cription of lasue 3.7.8 8 DOC LA.12 Ji'D llases P.18 CIS 3.7.4.2 ACTION a ITS 3.7.8 ACi10N 11 1IS 113.7.8 liasen . LCO CTS 3.7.4.2 ACTION a states "With one or both of the crosstie valves (s) closed and not capable of being opened from the Main Control Room, within 7 days restore the valve (s) to available status or open the affected vahe(s) and maintain the affected valve (s) open.. " lls 3.7.8 Condition I! changes this to opposite unit SX train inoperable". There is no discussion provided as to why an explicit 11S Required Action is not retained to " ..or open the affected valve (s), and maintain the afTected valve (s) open;..." 1his is not covered in LA.12 and there should be ajustification for this change. ITS 113.7.8 Ilases . LCO states that the now path from the unit is established or capable or being established.1his statement would suflice to meet the CTS ACTION seguirement since it would allow the valve to remain inoperable indennitely, Comment:

Revise the CTS /ITS mailup to include this CTS ACTION requirement and provide additional discussion and technical justification for these changes.

Comed Response to lisue Comlid disagrees. DOC 3.7 LA12 discusses why a specific ITS Required Action is not required for this level of detail and states, "C1S 3.7.4.1 and 3.7.4.2 include details of w hat constitutes operability of the opposite-unit SX System (pump, and crosstle either open or capable of being opened from the main control room). In addition CTS SR 4.7.4.2 lists equipment part numbers for the crosstic vah es. These details are selocated to the ITS liases.1hese details are not necessary to ensure the SX System is Operable. The deGnition of Operability suf0ces. The requirements of ITS LCO 3.7.8 are adequate for ensuring the SX System is operable. These details are not necessary to be in the TS to ensure the SX System can perform V) l its intended safety function. As such, these details are not required to be in the TS to provide adequate protection of the public health and safety. Including this level of detail in the 11ases rather than the Speci0 cations is consistent with 11S format guidelines. Any change to these details is made in accordance with the !!ases Control Program described in ITS Section 5.5." The crosstie vahe is only one example of what would require entry into ITS LCO 3.7.8 Condition 11. In addition, insert 113.7 4211(Item b.)to the ! CO Section of the liases states, "An opposite unit SX train is considered OpERAllLE during MODES 1,2,3, and 4 when: . b. A flow path from the opposite unit is established, or capable of being established (including the opposite unit crosstic valves ISX005 and 2SX005) . ." inherent in the phrase. *A 11 w path from the opposite unit is established " is the fact that the valve (s) are open and maintained open. Further, ITS SR 3.7.8.3 surveils this requirement. Comed centinues to pursue this change.

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~NHdtAIWuiIser NRClde~dIEte~ Y5i5tatus 3.7.8-09 12/$/97 Open.NRC Action Required NRC Description oflasue 3.7.89 DOC LA.13 JI D P.18 C1S 4.7.4.1.a.1 ITS SR 3.7.8.2 and Associated Bases CTS 4.7.4.1.a.1 requires that the opposite unit SX pump is capable of being manually started from the Main Control Room at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Justincation LA.13 states that this requirement is relocated to the TRhi, since these requirements consist of panel checks and verincation that the pump can be stated. This is not entirely true, ITS !! 3.7.8.2 Hases SR 3,7.8.2 states that the pump shall be started from the main control room on a 31 day frequency. Thus, CTS 4.7.4.1.a.1 is included in ITS SR 3.7.8.2 but with a Less Restrictive frequency. Comment: Revise the CTS markup to reDect this Less Restrictive change, and provide additional discussion andjustincation for this Less Restrictive change.

Comed Response to issue Comed disagrees. CTS 4.7.4.1.a.1 only requires a verincation that the SX pump is capable of being manually started from the hiain Control Room every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (I c., an indication and availability check only). This SR does not require starting the pump. 'the SR that requires the pump to run is CTS 4.7.4.1.b w hich is consistent with ITS SR 3.7.8.2. The ITS not the NURI O require any verincation that the pump can be started from the hiain Control Room. This requirement in the C1S did not meet the NRC 10C1 R$0.36(cX2Xil) criteria for inclusion into the ITS and therefore, is relocated to the TRht.

Verifying the pump can start every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and actually running the pump every 31 days are two different requirements.

Comed continues to pursue this change. DOC 3.7.LA13 will be revised to state,"... These requirements consist of panel checks and verincation that the opposite unit pump can be started from the control room, and verincation that a nowpath is established or capable of being established from the control room ... .' 'this change w ill be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Sect n 3.7 RAl.

NRC RAI Number NRC lisned Date RAI Status 3.7.8 10 12/$/97 Open.NRC Action Required NRC Description of Issue 3.7.8 10 DOC I A.13 CTS 4.7.4.1.a.2 ITS SR 3.7.8.1 ITS SR 3.7.8.3 and Associated Bases CTS 4.7.4.1.a.2 requires verifying that the SX system crosstic is established or capable of being established from the hiain Control Room at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This requirement is shown as being relocate by LA.13. LA.13 only discusses the rekication of CTS 4.7.1.a.1 (SX pump availability), not the cross-tie. This requirement is encompassed by ITS SR 3.7.8.1 and ITS SR 3.7.8.3 but not specincally stated in the associated Bases, in addition, the following would be Less Restrictive (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 31/92 days) Cuament: Revise the CTS'ITS markup to renect this l ess Restrictive change and provide additional discussion and justincation for this Less Restrictive change.

Comed Response to issue DOC 3.7 LA13 will be revised to state, " .. 'these requirements consist of panel chech and verincation that the opposite.

unit pump can be started from the control room, t.nd verincation that a Cowpath is established or capable of being established from the control room . . ." This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

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3.7.8 11 12/5/97 Open.NRC Action Required NRC Description ofluue 3,7.81I DOC L.9 C1 S 3,7,4.1 1IS 3.7.8 RA 11.1 CTS 3.7.4.1 is associated with opposite unit SX pump requirements. An exception to CTS 3.0.4 exists in CTS 3,7.4.2 for the SX crosstle, which provides the flow path for the opposite unit pump. Therefore, the ITS 3.7.8 RA 11.1 adds a Note which states "LCO 3.0.4 is not applicable", his is acceptable, however, the Note should additionally state that this is ,

applicable "for the unh specine SX System only", as is stated in the L9. Since the Note as written could apply to both units t when in this conditon, which is not the intent. Also, is the last sentence of L.9 correct in referencing ACTION A, rather t that ACTION 11; or, is there more than one subject being addressed 7 It appears there should be a new ACTIONS Note to .

Leep the opposite unit SX train from being used for opposite unit MODE changes while supporting the " remaining" unit.  ;

specine SX train. Comment: provide the additional discussion and technicaljustincation as required for this change.

Comed Response to lasue j Comed disagrees. As stated in DOC 3.7.L9, the LCO 3.0.4 caception is associated with the opposite unit, not the specinc <

unit. Therefore, the Note is appropriately located in ITS LCO 3,7.8 Condition 11 Required Actions. Ilowever, in the last sentence of DOC 3.7.L9, a typo was corrected to change " Action A" to " Action 11." 7hc sentence now reads,"This will allow the unit specinc unit to change modes while relying on Action 11 ofITS 3,7,8 which requires restoration of the opposite-unit pump in 7 days," %Is change will be provided in our comprehensive ITS Section 3.7 closcout submittal '

revision upon NRC's concurrence with the Comed Responses to the ITS Section 3,7 RAl.

NRC RAI Number NRC luned Date RAI Status 3,7,901' 12/$/97 Open . NRC Action Required NRC Description of luue (Byron only) 3.7,91 DOC A.I ,

(Hyron) Ji'D flases p.41 ,

CTS 3.7.5 ACTIONS ITS 3.7.9 ACTIONS and Associated liases The Ulls is shared between Units I and 2. There are no indications in the CTS that this system is shared between the units ,

and no indication ofinter unit dependence in the CTS, For example, w hen the systeu or a component in the system is  ;

inoperable and regardless of w hkh MODE cach unit may be in both units must simultaneously enter the appropriate i ACTIONS. The STS did not consider shared unit operation of a system. Therefore, this ITS needs an ACTIONS Note to clarify that both units will enter the appropriate ACTICNS. The new ACTIONS Note should state: "These ACTIONS shall  ;

apply to both units simultaneously," This note will create the inter unit dependence of the design. Comment: Revise the T CTS /ITS markups and liases to include this ACTIONS Note and provide the appropriate discussions and justincations.

Comed Response to issue No change,. Comed disagrees. There are several systems that are shared between the two units witich do not have any such '

i note added. Operators are trained that if a common system between the two units becomes inoperable, a unit specinc  !

OpERAlllLITY determination is made. In this case, if the UllS becomes inoperable, both units will be made aware and appropriate unit specific action will be taken This is consistent with other commonly shared systems, structures, or comp (ments. Comed continues to pursue this change, O

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DOC A.35 DOC A.48 DOC LA.30 IX)C1.A.31 DOC L.22 DOC L23 DOC L.24 JI D P.21 Ji'D liases P.42 C1s 3.7.5 ACTIONS A number of CTS 3.7.5 ACllONS have been overlooked and'or modined by the lack of a complete dennition of OPERAlllLITY for the UllS. Some of these CTS requirements have no equivalent ITS 3.7.9 ACTION requirements, others have been proposed as 114 3,7.9 SRs, and others have been included in plant specinc 11S 3.7.9 ACTIONS. These changes have been proposed and;ustined as Administratise ( A), Less Restrictive Relocated (LA) and Less Restrictisc (l.) change.

Some of w hich bas e inadequate justi0 cations, are beyond scope or review items, or constitute major changes in the operation of the UllS.1he succeeding comments highlight the major conserns and problems found by the staff. See item Numbers 3.7.9 3,3.7.9 4,3.7.9 5,3.7.9-6,3.7.910,3.7.91I and 3.7.9-13. Comment: h light of the above and the succeeding comments (see item Numbets 3.7.9 3,3.7.9-4,3.7.9 5,3.7.9 6,3.7.9-10,3.7.911, and 3.7.9 13). Licensee should re-evaluate or rethink the C1s ACTIONS and the ITS ACTIONS to assure that all the CTS UllS OPERAlllLITY n requirements have been addressed h Comi:d i esponse to lisue Comi:d has reviewed the NRC RAls and corrected the ITS ACTIONS where applicable. See Comlid responses to RAI 3.7.9-03,04,05,06,10, I I, and 13. These changer will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (See RAls 3.7.9 03, 04,05,06,10, i 1, and 13.)

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-NRC RAI Number NRC lasued I)ste RAI Status 3.7.9 03 12/$/97 Open. Comtid Action Required NRC I)escription ofissue (Dyron only) 3.7.9 3tX)C A.34

_ (Dyron) JfD P.21 JrD liases P.42

'..1S 3.7.$ ACilON a.

ITS 3.7.$ ACTION !! and Associated Danes CTS 3.7.5 ACTION a speclues that with a water level ofless than 50% in either UllS cooling tower basin, restore the water level to at least 50% in each Ulls cooling tower basin within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The CTS markup changes *either to *one" and

'ench* to *the" so that ITS 3.7.$ Condition il v/ould read 'One basin level <$0%" with a Required Action and Completion Time of

• Restore basin level to >$0% in "6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />" respectively. This change has been characterized as an Administrative change (A.34),1his change is not an administrative change but a More Restrictive change. As currently written CTS 3.7.5 ACTION a would allow one or both Ulls cooling tower basins to be inoperable due to water level. In that _ situation, petticularly with both basins out,6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed to restore both basins to OPERAllt.lbtatus, before a shutdown is required.1hc ITS would require an immediate shutdown per ITS 1.CO 3.0.3. Comment: Provide a discussion and justl0 cation for this more Restrictive change .

Comi'.d Response to issue 2/6/98 Corrected Response: Comed will revise ITS 3.7.9 Condition 11 and Required Action 11.1 to address basin les els consistent with CTS 3.7.$ Action a. Condition 11 will be revised to state, *One or more basin levels < $0%." Required Action 11.1 will be revised to state," Restore both basin levels to 50%." 1hese changes will be provided in our comprehensive ITS Section 3.7 closcout subraittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAI. (See RAls 3.7.9-02,04,05,06,10,11, and 13.)

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3.7.9-04 12/$/97 Open. Comed Action Required NRC Descript6en ofissue (llyron only) 3.7.9 4 DOC A.35 (llyron) DOC LA.30 DOC L.22 DOC L.23

- JfD p.21 Jr0 liases p.42 CTS 3.7.$ ACTIONS c and d.l, ITS 3.7.9 ACTION C and Associated llases CTS 3.7.$ ACTION C requires the restoration of the inoperable essential service water (SX) makeup pump in either 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (ACTION c.1) or 7 or 14 days depending on the plant conditions specified in ACTION c.2. A.35 states that the .

restoration time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is not included in the ITS 3.7.9 ACTION C. because ITS 3.0.2 allows restorative of the affected component within the time limits of the specified Required Action. L.22 states that the 7/14 day restoration time is based on -

the availability of other basin tr. keup sources.1hus, ITS 3.7.9 ACTION C la based on ITS. ACTION c.l for an inoperable cooling tower basin switch (Automatic SX makeup pun p start switch) which allows indefinite operation with an inoperable switch. This is unacceptable to the staff, however, the change in CTS 3.7.$ Action e from cooling tower basin switch to SX makeup pump is acceptable since the switch is a support component necessary for pump OPERAlilLITY. The curr.nt

' licensing basis requires pump restoration, which ITS 3.7.9 ACTION C does not require. In addition certain assumptions are made with regards to the alternate makeup sources which were not part of the initial staffieview. Therefore, the change based on L.22 is considered to be a beyond scope of review item for this conversion. Comment: Revise ITS 3.7,9 ACTION C to include the restoration of the inoperable SX maket.p pump to OPERAllt.E status in accordance with the CTS and

. provide additional discussions andjusti0 cations to support these required changes.

O' ComF,d nesponse to issue b Comed will revise ITS 3.7.9 Required Action C to include the restoration of the SX makeup pump to the OpERAllt.E status as Required Action C.3. This will require that the SX makeup pump be restored to the OpCRAllLE status within 7 days if both units are in MODE I.4, or 14 days if either unit is in MODE $ or 6. The ITS Bases will t.: enhanced for RA C.3 to include the reason for the 14 day allowance with either unit in MODE $ or 6 and a pump inspection and extended maintenance work window scheduled. CTS DOC L22 will be deleted. This change will be provided in our comprehensive

!TS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl (See RAls 3.7.9 02,03,05,06,10, i1, and 13.)

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35

I Response to NRC RAI Dated 12/05/97 Os.rch-9s l

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NRC RAI Nusuber - Sid'lossed Date RAIStatus 3.7.9-05 12/5/97 Own. Comed Action Required NRC Description of losue (llyton only) 3.7.9 $ DOC A.48 l

- (llyron) DOC L.24 ,

JFD P.21  ;

Ji'D P.22  ;

- JFD Ilases P.42 JFD Itases P.43 I CTS 3.7.$ AC110N g  ;

ITS ACTION D ITS SR 3.7.9.1 ,

ITS SR 3.7.9.4 and /.ssociated flases ,

CTS 1.CO 3.7.5 ACTION g provides one hour to conurm river level and flow, if river level is below 670.6 feel MSL ITS  !

. SR 3.7.9.4 conunns river level on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis, while SR 3.7.9.1 confirms river level and How on a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> basis ifITS ,

SR 3.7.9.4 is not met. The justl0 cation (A.48) states that if SR 3.7.9.4 is not met. ITS LCO 3.7.9 Condition D would be

- entered. Condition D requires verincation of basin levels and operability of one makeup source within I hour. There is always the option to restore compliance with the LCO within the stated Completion Time. Therefore, within the I hour, ITS SR 3.7.9.1 could be performed and if the SR was met, Condition D exited." This is not true. IfITS SR 3.7.9.4 is not met, then ITS SR 3.7.9.1 must be met, which would require the immediate performance of this SR. It is conceivable at this

, time that ITS SR 3.0.3 could apply thus allowing 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to perform this SR, before entering ITS 3.7.9 ACTION D. This is not the intent of the CTS or the ITS. The staff believes that CTS 3.7.5 ACTION g.1 should be retained as a separate ITS ACTION, ITS SR 3.7.9.1 be deleted and ITS ACTION D be modified to include an additional condition for Required Action and Associated Completion Time of the river level ITS ACTION not mec Comment: Revise the CTS /11S submittal along the lines suggested and provide appropriate additional discussions andjusti0 cations.

ComF.d Response to 16 sue -

Comed agrees that the requirement to verify rL er level and How within one hour in accordance with the requirements of CTS 3.7.5.g should be included in SR 3.7.9.1 and not depend on the Required Action of Condition D. SR 3.7.9.1 would require an initial I hour, and every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereaner, surveillance frequency if river level is below 670.6 feet MSL. Com Ed does not agree that ITS Required Action D should be modified to include the additional actions for river level, ITS SR 3.7.9.4 will continue to con 0rm riv devel en a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis, while SR 3.7.9.1 confinns river level and now within I hour from the failure do meet the requirernents ofITS SR 3.7.9.4 and every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereaner ifITS SR 3.7.9.4 is not met. DOC A48 will be deleted and JFD P22 will be revised to include the requirements of CTS 3.7,$.g. This change will be provided ,

in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to

' the ITS Section 3.7 RAL (See RAls 3.7,9-02,03,04,06,10,11, and 13.)

36

Response to NRC RAI Dated 12/05/97 0. orch-98

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khfC' Issued Date RAI Status 3.7.9-06 12/5/97 Open Comed Action Required NRC Description of Iseue (Byron only) 3.7.9 6 DOC LA.24 (Byron) DOC L.22 CTS 4.7.5 e A CTS 4.7.5a CTS 4.7.5.e.4 and CTS 4.7.5.i require starting the deep well pumps every 31 days and verifying the flow rate once per 18 months. The deep well pumps are not included in ITS 3.7.9 since they are consider as the backup to the SX makeup pumps The CTS requirements are relocated to the TRM which is acceptable. Ilowever, thejustification (LA.24) states that the pumps are not directly related to UllS OPERABILITY. This is incorrect. Even though this backup system is a Class 11 system (per L.22), it serves as a support system to the UllS, thus is directly related to UliS OPERAlllLITY in th lit is directly related to UllS OPERABILITY in that ifit is inoperable ITS 3.7.9 ACTION E would have to be entered.

Comment: Corrected this raor in justification LA.24.

Comed Response to issue 2/6/98 Corrected Response: Comed disagrees that the deep well pumps are directly related to UllS OPERABILITY. If a deep well pump was declared inoperable with the SX makeup pumps OPERABLE, there would be no reason to enter ITS 3.7.9 Condition E and conduct a plant shutdown. The deep well pumps are only required to be OPERAllLE w hen one of the SX makeup pumps is inoperable, or when weather conditions require a backup source to be operable. Comed continues to pursue this change. (See RAls 3.7.9-02,03,04,05,10, i1, and 13.)

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Response to NRC RA! Dated 12/05/97 Os-reb-98

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NRC RAI Number NRC lssued Date liU Str.tus 3.7.9-07 12/5/97 Cren NRr., Actien Required NRC Description ofissue (Byron only) 3.7.9-7 DOC LA.25 (Byron) CTS 4.7.5.c.1 CTS 4.7.5.f CTS 4.7.5.h L

CTS 4.7.5.e.1,4.7.5 f and 4.7.5.h detail requirements for the OFERAB:LITY of the diesel portions t.f the diesel driven SX makeup pumps. These requirements are not inciuded in ITS 3.7.9 but have been relocated to TRM. While the diesel inspection requirement for CTS 4.7.5.h (see item Number 3.7.9-8 for valve requirements) can be relocated (See item Number 3.7.5-2), the other diesel requirements must be maintained in the ITS. See item Number 3.7.5 2 for the reasons for retention. Comment: Revise the CTS and ITS submittals hecording the dis ussion in item Number 3.7.5 2 and provide any additional discussion and justification to support these changes.

Comed Response to Issue No change. Comed disagrees that CTS 4.7.5.e.l. 4.7.5.f and 4.7.5.h need to be incorporated into the ITS. The infonnat!an contained in these CTS SRs require that in order for the diesel pow cred essential service water makeup pump to be demonstrated OPERABLE, the fuel supply tank shall maintain a volume of 36% diesel fucl oil. This is to be verified every 31 days. Every 92 days the drain sample of diesel fuel from the fuel storage tank is obtained and tested in accordance wit .

a specified ASTM. In addition, every 18 months the diesel shall be inspected in accordance with the manufacturer's

} recommendations. The NRC reviewer states Jiat the staff finds relocating these requirements to the TRM is unacceptable

[ and they are needed to demonstrate OPERABILITY of the diesel pump. Essentially all CTS SRs make a generic R introductory statement that a specific componem or piece of equipment shall be demonstrated OPERABLE by the successful performance of a specific SR. Almost all of the CTS SRs relocated to the TRM contain the exact same statement 7

of demonstrating OPERABILITY through the performance of the SR. The difference betw:en retaining specilic

% t requirements in the ITS or relocating them to a licensee controlled document (i.e., TRM) is if the requirement meets the j NRC criteria as stated in 10CFR50.36(e)(2)(ii). In this specific case, the requirements being relocated do not meet the NIF acceptance criteria as stated in 10CFR50.36(c)(2)(ii). Relocating the subject SRs to a licensee controthd document does not eliminate these requirements, does not change frequency of verifying the diesel fuel oil volume, nor eliminate any inspections being performed in accordance with the manufacturer's recommendations. Comed feels that these requirements are still essential and relocating them to a licensee controlled document does not in any way lessen their importance. Once these requirements are maintained in a licensee controlled document any changes would be subject to a 10CFR50.59 evaluation. In addition, all the STS 3.7.5 SRs as stated in NUREG-1431, are mamtained in toe ITS with minor changes made to nccommodate plant design and current licensing basis. These SRs have been identified by the NRC and industry as adequate to demonstrate OPERABILITY from a STS point of view. Based on the fact that the subject requ4ements are maintained in a licensee controlled document as required by 10CFR50.36(c)(2)(ii) the ITS will not be revised to incorporate these requirements. Comed continues to pursue this change.

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38

1 Response to NRC RAI Deted 12/05/97- 05-r4b-98

~NRC RAI Nunnwr 'Wssued Date RAI Status  !

/ 3.7.9 08 12/5/97  : Open NRC Action Required b -

NRC Description ofissue '

(Byron only) 3.7.9 8 DOC LA.25 t (Byron) - CTS 4.7.5.h CTS 4.7.5.h in addition to requiring an 18 month inspection of the SX pump diesel also requires " cycling each testable valve in the flow path through at least one complete cycle of full travel." The CTS markup shows this requirement as being i relocated (LA.25), but nojustification is provided to show that it can be relocated or to which licensee controlled document. Since other CTS LCOs which require vahre cycling have included this requirement in the associated ITS SRs; this requirement should also be included in ITS 3.7.9. Comment: Revise the CTS /ITS markup to retain this valve cycling require and provide appropriate discussion andjustincation.

- ComFd Response to issue This requirement is being relocated to the TRM in accordance with the NRC 10CFR50.36(c)(2)(ii). DOC LA25 will be -

revised to specincally state this relocation. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

NRC RAI Numtwr NRC Issued Date RAI Status 3.7.9-09 12/5/97 Open-NRC Action Required NRC Description ofIssue (Byron only) 3.7.9 9 DOC LA.28 (Byron) CTS 4.7.5.d ITS B3.7.9 Bases SR 3.7.9.5 m

( ') CTS 4.7.5.d details design attributes of how to perform the Ulls fan surveillance (e.g., by starting from the control room).

'V These items are to be relocated to the TRM and to the ITS Bases. The de' ail on starting the fan from the control room for this surveillance has not been relocated to ITS B 3.7.9 Bases SR 3.7.9.5 as stated above. Comment: Include this item in the discussion ofITS B 3.7.9 Bases - SR 3.7.9.5 or provide additional discussion andjusti0 cation to show why it should not be relocated there.

Comed Response to issue Comed will relocate the detail of starting the fan from the control room for the performance of SR 3.7.9.5 to the ~

Surveillance Requirements Section of the Bases for ITS LCO 3.7.9. This change will be provided in our comprehensive ITS Section 3.7 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAI, 39

Resp 2nse to NRC RAI Dsted 12/05/97 Os-red-9s NRC RAI Number NRC lisued Date RAI Status h

G 3.7.9 10- 12/5/97' Open. Comed Action Required NRC Description ofissue

- (Byron only) 3.7.910 - DOC LA.30 (Byron) DOC L.24

. JFD P.21 -

JFD Bases P.42 CTS 3.7.5 ACTION c.2 CTS 3.7.5 ACTION g.2 ITS 3.7.9 ACTION D and Asweiated Bases CTS 3.7.5 does not include specific ACTIONS for the case of two inoperable SX makeup pumps except for inoperability-due to river water level and cooling tower basin switches. Therefore, CTS LCO 3.0.3 would apply for all other SX makeup pump inoperabilities. ITS 3.7.9 ACTION D tries to combine the modified CTS 3.7.5 ACTIONS c.2 and g.2 for two SX makeup pumps inoperable. LA.30 changes the words in CTS 3.7.5 ACTION e.2 from " cooling tower level basin switches" to SX makeup pumps." While this may be an acceptable change for oc switch /one pump inoperable, it may not be for two switches /two pumps inoperable. With 2 cooling tower level basin switches inoperable, the Required Actions of CTS 3.7.5 ACTION c.2 takes into account the manual start /stop capabilities of the SM makeup pumps, and the alternate makeup source. This particular aspect of CTS 3.7.5 Actim c.2 has not been addressed in either LA.30 or L.24. See item Numbers -

3.7.913. Comment: Provide additional discussion andjustification on this aspect of CTS 3.7.5 ACTION e.2 and its effect on the conversion to ITS 3.7.9 ACTION D.' See item Number 3.7.913.

Comed Response to issue Comed disagrees. As stated in DOC 3.7 LA30 the level switch function is considered part of the SX makeup pumps OPERABILITY and discussed in the LCO Section of the Bases for pump OPERABILITY with changes justined by Bases JFDs P41 and P42 and LCO JFD P21. If one of the level switches were to become inoperable and unable to perform its O intended function, then one SX makeup pump would be declared inoperable and Condition C entered. With two level V switches inoperable, two SX makeup pumps would be inoperable and Condition D would be entered. With two cooling tower level basin switches inoperable, Required Actions of Condition D ofITS 3.7.9 take into account the manual start /stop capabilities of the SX makeup pumps with the dennition of an associated makeup source discussed in the Actions Section of the Bases for Required Action C. Comed continues to pursue this change. (See RAls 3.7.9-02,03,04,05,06,11, and 13.)

O 40

Response b NRC RAI D:t:d 12/05/97 Os-reb-98

~NiiCif TNumber NiiC lssued Date RAI Status (v ) 3.7.9-11 12/5/97 Open Comed Action kequired NRC Description of Issue (Byron only) 3.7.9-11 DOC LA.31 (Byron) JFD P.21 JFD flases P.41 JFD Bases P.42 CTS 3.7.5.f CTS 3.7.5.h CTS 3.7.5 ACTION f CTS 3.7.5 ACTION h ITS 3.7.9 ACTION D and Associated Bases CTS 3.7.5.f and 3.7.5.h specify that UllS OPERABILITY is dependent on the National Weather Service (NWS) forecasts of Rock River flood level and tornados respectively. CTS 3.7.5 ACTIONS f and h are the remedial actions that are taken when the NWS forecasts high river level (>702 n.) and tornados respectively. While the staff agrees in part that these anticipatory actions can be relocated from the CTS to licensee controlled documents, the staff does believe that these anticipatory actions should be relocated to the plant emergency procedures or operating procedures due to the safety significance of the conditions. Ilov,ever, it is also the staff's position that CTS 3.7.5 ACTIONS f and h be retained in some form in the ITS. The reason for this is even though both ACTIONS are anticipatory actions to be taken prior to the occurance of the conditions or event, both ACTIONS also apply afler the event has occurred and exiting the ACTIONS will depend on when the event ends. Even though both ACTIONS deal with two SX makeup pumps inoperable (CTS 3.7.5 ACTION f river water level > 702 ft and CTS 3.7.5 ACTION h river water level < 664.7 ft) the CTS ACTIONS are either More Restrictive or Less Restrictive than ITS ACTION D. Comment: Revise the CTS /ITS markup to include CTS 3.7.5 ACTIONS f and h in ITS 3.7.9 and provide the appropriate discussions andjustifications for the proposed changes.

A Comed Response to issue Comed disagrees. As the staff has suggested, current Byron Operating Abnormal procedures , OBOA ENW1 Adverse Weather Conditions and OBOA ENV.2 Rock River Abnormal Water L.evel contain all of the Required Actions of CTS 3.7.5 Actions f and h, When contacted by the NWS of the issuance of a tomado watch or warning or of the Rock River exceeding the flood level requirements for SX makeup pumps OPERABILITY, these procedures are entered and the appropriate actions taken. Once the event is declared, the procedures and Actions are in effect until the event has been

'erminated and the BOA exited. The NRC reviewer states that the Staff finds relocating these requirements to the TRM is acceptable but may be exited prior to the event ending; however, the original condition to enter the TRM Specification would not have been declared as over not allowing exiting of the requirement. Essentially all CTS SRs make a generic introductory statement that a specific component or piece of equipment shall be demonstrated OPERABl.E by the successful performance of a specific SR. Almost all of the CTS SRs relocated to the TRM contain the exact same statement of demonstrating OPERABILITY through the performance of the SR. The difference between retaining specific requirements in the ITS or relocating them to a licensee controlled document (i.e., TRM) is if the requirement meets the NRC criteria as stated in 10CFR50.36(c)(2)(ii). Comed continues to pursue this change. (See RAls 3.7.9-02,03,04,05, 06,10, and 13.)

p 41 ,

1

~

- Response to NRC RAI Dated 12/05/97 os-reb-9s NRC RAI Numtwr NRC issued Date RAI Status 3.7,0 12- 12/3/97 Open-NRC Action Required NRC Description of issue

- (Byron only) 3.7.912 DOC L.5

_ (Byron) JFD P.30 JFD 11ases P.43

' CTS 4.7.5.e.2 -

ITS SR 3.7.9.7 .

CTS 4.7.5.e.2 verifies every 31 days the starting of the diesel from ambient conditions on a low basin level test signal. ITS SR 3.7.9.7 has changed this Frequency to be consistent with the IST Program. The justification for this change is unacceptable; consistency with the NUREO is not a justification for changing a Frequency. Comment: Revise the submittal to provide the additional discussion and technicaljustification for this Less Restrictive change.

. Comed Response to Issue No change. The 31 day Frequency did not change. The Frequency statement in the NUREO of,"in accordance with the Inservice Inspection Testing Program" was used in ITS 3.7.9.7. The 31 days has been incorporated into the IST Program.

Co uEd has not made any Frequency changes for this SR. Comed continues to pursue this change.

.Di k

42 j

r

=__ _ . _ _ .

, Response 13 NRC RAI D:ted 12/05/97 05-reh-98 i

NRC RAI Number NRC issued Date RAI Status 3.7.9 13 12/5/97 Open Comed Action Required NRC Description of issue (llyron only) 3.7.913 DOC L.24

(!!yron) JFD P.30 JfD !!ases P.43 CTS 3.7.5 ACTON c.2 CTS 3.7.5 ACTION g.2 ITS 3.7.9 ACTION D ar.d Associated Bases CTS 3.7.5 ACTIONS e.2 and g.2 are modified by justification L.24 and combined into ITS 3.7.9 ACTION D. L.24 states that the modification places the plant in a condition where the safety function assumed in the design basis analysis can be satisfied and is consistent with CTS 3.7.5 ACTIONS c.2 and g.2. This is not true. See item 3.7.9-10 for one aspect of this problem. CTS 3.7.9 ACTION g.2.a requires that both deep well pumps be verified OPERABLE within I hour not one pump in one hour and the other in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as proposed in ITS 3.7.9 ACTION D. CTS 3.7.5 ACTION g.2.b specifies the requirements with one deep well pump inoperabic, implicit in this ACTION is that the cooling tow er basin levels could be below 82%. Thus 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> would be allowed to not only restore the pump to OPERABLE status but also the basin water level. ITS 3.7.5 ACTION D does not allow this, ITS 3.7.5 ACTION E, immediate shutdown, would have to be entered. In addition ITS 3.7.5 AC flON D has a Note which states that "LCO 3.0.4 is not applicable." This note applies to all of ACTION D. In the CTS the provisions of CTS LCO 3.0.4 only apply if both deep well pumps are OPERABLE, the ITS would allow this to apply if one deep well pump is inoperrSle. Based on the above as well as other items, ITS 3.7.5 ACTION D needs major rework. See item Number 3.7.9-11. Comment: Revise CTS /ITS markup to correcity reucct the design and current licensing basis for two SX makeup pumps inoperable and provide the appropriate additional discussions and justifications to support the proposed changes.

Comed Response to issue

]

[J Comed agrees that in order to correctly apply the Note for 3.0.4 not applicable anuther Condition (Condition E) should be added. This would allow Condition D to address the inoperability of two SX makeup pumps by verifying both SX basin levels at greater than 82% and the OPERAlllLITY of both makeup sources within one hour. To be consistent with CTS 3.7.5.g.2.b), if one of the deep well pumps were inoperable, a Condition E would address both SX basin levels at greater than 82% and also would require verification of the OPERABILITY of at least I makeup sources, with the requirement to restore the inoperable makeup source to OPERABLE status within a 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 kAI. Comed disagrees: As stated in DOC 3.7-LA33 for CTS 3.7.5.g, the level and flow of the river is considered part of the SX makeup pumps OPERABILITY and is discussed in the LCO Section of the Bases for pump OPERAlllLITY, As directed by CTS 3.7.5.g, if the level of the Rock River were to go to 664.7 feet MSL or less, both SX makeup pumps would be declared inoperable and Condition D entered. With two inoperable SX makeup pumps, Condition D would require that both SX basin levels be verified at greater than or equal to 82% and also would require verification of the OPERAlllLITY of both makeup sources (i.e., only deep well pumps Operable). Consistent with CTS 3.7.5.g.2.b) the prorosed Condition E would define if one of the deep well pumps were inoperable, a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is granted to restore both deep well pumps to the OPERABLE status. (See RAls 3.7.9 02,03,04,05,06,10, and 11.)

4./

43

Response b NRC RAI Dded 12/05/97 os-rah-98

~dRC RAI Number L NRC issued Date RAI Status

~ 3.7.9 14 12/5/97 Open NRC Action Required NRC I)escription oflasue (Byron only) 3.7.914 DOC L.24 (Byron) CTS 3.7.5 ACTION g.2).c)

CTS 3.7.5 ACTION g.2).c) requires the plant to be placed "in at least ilOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at least ilOT SilUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at least COLD SilUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The CTS markup deletes the words "and at least ilOT SilVTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />." ne deletion is designated L.24. Justi0 cation L.24 does not address this deletion. Comment: Provide a d:scussion andjustincation for this deletion.

Comed Response to issue Comed will revise DOC L24 to include a discussion on deleting the requirement for going to llOT SilUTDOWN. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAI.

NRC RAI Number NRC Issued Date RAI Status 3.7.9 15 12/5/97 Open - NRC Action Required NRC Description ofIssue

- (Byron only) 3.7.915 JFD Bases B.20 (Byron) CTS 3.7.5.d

- CTS 4.7.5.b l ITS SR 3.7.9.3 and Associated Bases L

l CTS 3.7.5.d and 4.7.5.b specines the UllS temperature limits which are to be taken at the discharge of the SX pump. ITS l g'j 3.7.9.3 and its \ssociated Bases specifies the temperature limits, but does not specify the location (SX pump discharge).

This should be reaccted in the Bases discussion for ITS SR 3.7.9.3 since it is a plant specinc detail. Comment: Revise the j CTS /ITS markup to show the relocation from the CTS and the inclusion in the ITS Bases of this detail and provide the-appropriate discussions and justi6 cations for this Less Restrictive change.

Comed Response to Issue I

Comed will revise Bases SR 3.7.9.3 to specify the UllS temperature (s) are to be taken at the discharge of the SX pump.

This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

44

Response to NRC RAI Dated 12/05/97 es reb 9s NRC RAI Number NRC lisued Date RAI Status 3.7.9 16 12/5/97 Open NRC Action Required -

' NRC Description ofissue (Braidwood only) 3.7.916 DOC A.I (firaidwood) _ JFD Bases P.19 CTS 3.7.5 ACTIONS ITS 3.7.9 ACTIONS and Associated Bases -

The Ulls is shared between Units I and 2. There are no indications in the CTS that this system is shared between the units and no indication of inter unit dependence in the CTS. For example, when the system is inoperable and regardless of which MODE er.ch unit may be in both units must simultaneously enter the appropriate ACTIONS. The STS did not consider shared unit operation of a system. Therefore, the ITS needs an Actions Note to clarify that both units will enter the appropriate ACTIONS. The new ACTIONS Note should state: "These ACTIONS shall apply to both units simultaneously." This Note will create the inter-unit dependence of the design. Comment: Revise the CTS /ITS markups and Bases to include this ACTIONS Note and provide the appropriate discussions andjustilications.

Comrd Response to issue No change. Comed disagrees. There are several systems that are shared between the two units which do not have any such note added. Operators are trained that if a common system between the two units becomes inoperable, a unit specific OPERABILITY determination is made, in this case, if the Ulls becomes inoperable, both units will be made aware and appropriate unit-specinc action will be taken. This is consistent with other commonly shared systems, structures, or components. ITS is consistent with the meaning and intent of CTS, and the licensed Operators are very well trained in, and familiar with, the application of technical speci0 cations to shared system inoperabilities. Comed continues to pursue this change. (See RAls 3.7.10-01,3.7.1101, and 3.7.12-01.)

-p NRC RAI Number NRC issued Date RAI Status -

3.7.9 17 12/5/97 Open NRC Action Required NRC Description ofissue (Braidwood only) 3.7.917 DOC LA.14

- (Braidwood) CTS 4.7.5.2 ITS 3.7.9 CTS 4.7.5.2 requires the performance of a hydrographic survey every 18 months to verify no degradation of the UllS. ITS 3.7.9 does not contain this plant specific surveillance 'Ihe statedjustification (LA.14) for relocating this requirement is based upon the STS does not contain a similar requirement or this level of detail. This is technically inadequate. While the staff agrees that CTS 4.7.5.2.b (UllS slope degradation) can be relocated to the TRM, it does not agree that CTS 4.7.5.2.a can be relocated. While slope degradation is important to UHS OPERABILITY, it is a subjective verification and is less critical than maintaining the necessary depth to assure an adequate water supply for the UHS. The depth verification (CTS 4.7.5.2.a) is analogous to maintaining a specific UHS water level (CTS 4.7.5.1 and ITS SR 3.7.9.1). Therefore the staff requires this requirement to be retained. Comment: Revise the CTS /ITS markup to retain CTS 4.7.5.2.a and provide additional discussion andjustifications to support the retention of CTS 4.7.5.2.a and the relocation of CTS 4.7.53.b.

Comed Response to issue No change. Comed disagrees. ITS SR 3.7.9.1 only requires that the UHS water level be verified every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This is in full compliance with NUREG 1431. The NRC reviewer is requesting Comed to deviate from the NUREG by incorporating the bottom level of the Ultimate lleat Sink (UllS) into the SR. The CTS currently contains the bottom level however, in accordance with the NRCs 10CFR50.36(c)(2)(ii) criteria, this information is relocated into the TRM. Relocating this requirement into the TRM does not lessen the need or importance of monitoring the bottom level of the Ulls or reduce its frequency. Once in the TRM, any changes to the requirement must be made in accordance with the 50.59 process.

Relocating this requirement to the TRM is consistent with other important parameters that need to be retained in a licensee O controlled document and not the ITS. Comed continues to pursue this change.

45 i

j

t Respons to NRC RAI D :t:d 12/05/97 Os-Feb-98 NRC RAI Number NRC issued Date RAI Status

, 3.7.10-01 12/5/97 Open NRC Action Required NRC Description ofissue 3.7.10-1 DOC A.1 JFD Bases p.21 CTS 3.7.6 ACTIONS ITS 3.7.10 ACTIONS and Associated Bases

%c Control Room Ventilation System is two independent trains which serve one control room envelope that is shared -

between Units I and 2. Dere are no indications in the CTS that this system is shared between the units and there is not

, indication ofinter unit dependence in the CTS. For example, when one train is inoperable and regardless of which MODE cach unit may be in, both units must simultaneously enter the appropriate ACTIONS. The STS did not considered shared

, . unit operation of a system therefore, the ITS needs an ACTIONS Note to clarify that both units will enter the appropriate -

ACTIONS. The new ACTIONS Note should state: "These ACTIONS shall apply to both units simultaneously." This Note will create the inter unit dependence of the design. Comment: Revise the CTS /ITS markups and Bases to include this

.~ ACTIONS Note and provide the appropriate discussions andjusti0 cations.

Comed Response to Issue -

No change. Comed disagrees. There are several systems that are shared between the two units which do not have any such note added. Operators are trained that if a common system between the two units becomes inoperable, a unit speci0c OPERABILITY determination is made. in this case, if the control room ventilation becomes inoperable, both units will be a

made aware and appropriate unit-speci0c action will be taken. This is consistent with other commonly shared systems, j structures, or components. ITS is consistent with the meaning and intent of CTS, and the licensed Operators are very well trained in, and familiar with, the application of technical speci0 cations to shared system inoperabilities. Comed continues

+

to pursue this change. (See RAls 3.7.916,3.7.11-01, and 3.7.12-01,)

' O (y NRC RAI Number NRC lssued Date RAI Status

3.7.10-02 12/5/97 Open. NRC Action Required 3

NRC Description ofIssue 7 3.7.10-2 DOC LA.17 CTS 4.7.6.b p, ' ITS B3.7.10 Bases LA.17 specines that the details of system OPERABILITY, design and methods of performing'SRs are relocated to the ITS

{ B3.7.10 Bases. CTS 4.7.6.b specifies that the VC Filtration System be tested "at least once per 31 days on a STAGGERED TEST B ASIS by initiating from the control room... and verifying that the system operates for at least 10 continuous 4

hours... " the "by initiating from the control room" is to be relocated by LA.17 to ITS B3.7.10 Bases. This detail has not been relocated to ITS B 3.7,10 Bases. Comment: Revise ITS B.3.7.10 Bases to include this detail.

Comed Response to Issue Comed will revise the Surveillance Requirements Section of the Bases for ITS LCO 3.7.8 to include that now shall be

. initiated from the control room for SR 3.7.10.1. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

a 46

Response to NRC RAI Dated 12/05/97 Os-reb-9s

? NRC RAI Number NRC issued Date RAI Status O 3.7.10 03 12/5/97 Open NRC Action Required d NRC Description ofIssue 3.7.10-3 JFD C 9 STS 3.7.10 APPLICABILITY ITS 3.7.10 APPLICABILITY ITS 3.7.10 APPLICABILITY modifies STS 3.7.10 APPLICABILITY to place semicolons between MODES and specified conditions and to use "and"s between APPLICABILITY specified conditions. This generic change is described in C 9 as WOG 81, it is the staffs understanding that WOG 81 has been rejected by the Owners Group. Comment: Delete this -

generic change.

Comed Response to issue

- WOG 81 will be withdrawn in its entirety throughout the ITS submittal. The submittal will be revised to adopt the STS presentation in the Applicability Section. This change will be provided in our comprehensive ITS Section 3.7 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (See RAls 3.7.1102, RAI 3.7.13-06,3.9.4-06, and 3.9.7-05.)

NRC RAI Number NRC Ismed Date RAI Status 3.7,10-04 12/5/97 Open NRC Action Required NRC Description ofissue 3,7.10-4 JFD Bases P.21 STS B3.7.10 Bases - BACKGROUND ITS B3.7.10 Bases BACKGROUND STS B3.7.10 Bases BACKGROUND, the last sentence of the eighth paragraph states "The CREFS is designed in accordance with Seismic Category requirements." This sentence has not been adopted in the ITS. Bases P.21 does not explain this deletion. Comment: Provide additional discussion andjustification to explain why this STS text was not adopted.

Comed Response to issue Comed will conform to the STS. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Eection 3.7 RAI. (See RAI 3.7.11 3.)

(

\

O 47

Response to NRC RAI Dated 12/05/97 05-reb-98 NRC RAI Number NRC issued Date RAI Status O

v 3.7.11 01 12/5/97 Open NRC Action Required NRC Description of issue 3.7. I l .1 DOC A.I JFD Bases P.21 CTS 3.7.6 ACTIONS ITS 3.7.11 ACTIONS and Associated Bases Comment: See item Number 3.7.101 Comed Response to issue No change. Comed disagrees. There are several systems that t.re shared between the two units which do not have any such note added. Operators are trained that if a common system between the two units becomes inoperable, a unit-specific .

OPERABILITY determination is made. In this case, if the control room ventilation temperature control system becomes inoperable, both units will be made aware and appropriate unit specific action will be taken. This is consistent with other commonly shared systems, structures, or components. ITS is consistent with the meaning and intent of CTS, and the licensed Operators are very well trained in, and familiar with, the application of technical specifications to shared system inoperabilities. Comed continues to pursue this change. (See RAls 3.7.916,3.7.10-01, and 3,7.12-01.)

NRC RAI Number NRC issued Date RAI Status 3.7.11-02 12/5/97 Open NRC Action Required NRC Description ofissue 3.7.11 2 JFD C.9 STS 3,7.11 APPLICABILITY l ITS 3.7 ll APPLICABILITY ITS 3.7,11 APPLICABILITY modifies STS 3.7.11 APPLICABILITY in accordance with WOG 81. See item Number 3.7.10-3. Comment: See item Number 3.7.10-3.

Comed Response to issue WOG 81 will be withdrawn in its entirety throughout the ITS submittal. The submittal will be revised to adopt the STS presentation in the Applicability Section. This change will be provided in our comprehensive ITS Section 3.7 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (See RAls 3.7.10-03, RAI 3.7.13 06,3.9.4-06, and 3.9.7-05.)

NRC RAI Number NRC issued Date RAI Status 3.7.11 03 12/5/97 Open NRC Action Required NRC Description ofissue 3.7.113 . JFD Bases P.21 STS B3.7.ll Bases APPLICABLE SAFETY ANALYSES ITS B3,7.ll Bases APPLICABLE SAFETY ANALYSES The fourth sentence of the second paragraph in STS B3.7.11 Bases - APPLICABLE SAFETY ANALYSES states "The CREATCS is designed in accordance with Seismic Category I requirements." This sentence has not been adopted in the ITS. Bases P.21 does siot explain this omission. Comment: Provide additional discussion to explain why this STS text was not adopted.

Comed Response to issue Comed will conform to the STS. This change will be prov:Jed in our comprehensive ITS Section 3.7 closeout submittal

. revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (See RAI 3.7.10-4.)

v 48

R:sponse to NRC RAI Dat:d 12/05/97 Os-reb-9s

. _ . .NRC RAI Number- NRC issued Date -RAI Status 3.7.12-01 12/5/97 Open NRC Action Required NRC Itseription ofissue 3.7.12 1 DOC A.1 JFD Bases P.28

. CTS 3,7.7 ACTIONS ITS 3.7.12 ACTIONS and Associated liases Acwrding to ITS 10.7.12 Bases BACKGROUND the description of the Nonaccessible Area Exhaust Filter Plenum Ventilation System, states that this system is a subsystem of the common Auxiliary Building ileating Ventilation and Air Conditioning System, and is also a shared system between the Units I and 2. There are no indications in the CTS that this system is shared between the Units and is no indication ofinter utill dependence in the CTS. The STS did not consider shared unit operation of a system and therefore, the ITS needs to be modined to take this into account, insuf0cient in'ormation on system design and operational alignments has been provided to determine if a Note similar to that proposed for ITS 3.7.10 ACTIONS and ITS 3.7.11 ACTIONS (See item Numbers 3.7.10-1 and 3,7.11 1)is sufficient to correct the concern or a total revision of the ACTION statements is necessary, Comment: Revise the submittal to account for the inter-unit dependence of the shared Nonaccessible Area Exhaust Filter Plenum Ventilation System and provide additional discussion and justifications, es appropriate.

Comed Response to issue No change. Comed disagrees. There are several systems that are shared between the two units which do not have any such note added. Operators are trained that if a common system between the two units becomes inoperable, a unit-specific i

OPERABILITY determination is made. In this case,if the nonessential area exhaust filter plenum ventilation system becomes inoperable, both units will be made aware and appropriate unit specific action will be taken. This is consistent with other commonly shared systems, structures, or components. ITS is consistent with the meaning and intent of CTS, and the licensed Operators are very well trained in, and familiar with, the application of technical soeci0 cations to shared system

. .Q inoperabilities. (See RAls 3.7.916,3.7.10 01, and 3.7,1101.)

%)

NRC RAI Number NRC issued Date RAI Status 3.7,12-02 12/5/97 Open-NRC Action Required NRC Description ofIssue 3.7,12-2 DOC A.44 DOC A.45 DOC LA.38 JFD P.12 JFD P.13 JFD Bases P.28 CTS 3.7.7 ITS LCO 3.7,12 ITS B3.7.12 Bases - LCO CTS 3.7.7 has been modined by a TS amendment request dated August 23,1996, This CTS change is under review by the steff, and is expected to be issued in October,1997. This beyond scope of review item will be evaluated for inclusion in the conversion upon issuance of the amendment in October,1997. Comment: Review of this beyond scope of review item is pending resolution of the August 23,1996 TS amendment request.

Comed Response to issue No change. This amendment was submitted at the request of NRR in an effort to further clarify the requirements for the standby plenum. This is an open issue until the NRC has reviewed and approved Comed amendment request dated August 23,1996.

O 49

Response to NRC RAI Dated 12/05/97 Os-reb-9s NRC RAI Number NRC issued Date RAI Status 3.7.13 0I  :-12/5/97 Open.NRC Action Required NRC Description ofissue 3.7,13 1 DOC M.9 JfD P.16 JFD Bases P.38 CTS 4.9.4.2 ITS SR 3.7.13.3 Note and Associated Bases A Note has been added to CTS 4.9.4.2 to state when this SR shall be performed. it is acceptable to add this new Note; however, in order to limit its performance when the equipment hatch is not intact during refueling, then the ITS 133.7.13 Ilases SR 3,7,13.3 should state that the SR is only required during movement ofirradiated fuel assemblies (whether inside containment or inside the fuel handling building) or Core alternations with the equipment hatch not intact. This change will

- bring the Itases discussion into conformance with the interpretation of this Note as stated in M.9, P.16, and Bases P.38.

Comment: Revise the submittal and CTS markup and provide additional discussion and technicaljusti0 cation for this change.

Comed Response to lasue The Survel' lance Requirements Section of the Ilases for LCO 3.7.13 has been revised for SR 3.7.13.3 from the original wording, "7his SR is modified by a Note that requires this SR only during movement ofirradiated fuel assemblies or CORE ALTERATIONS when the equipment hatch is not intact," to read, "This SR is modined by a Note that requires this SR only during movement of irradiated fuel assemblies (in the fuel building or in the containment) or CORE ALTERATIONS when the equipment hatch is not intact." This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3,7 RAl.

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50 l

Respo:tse to NRC RAI D:ted 12/05/97 os Feb 9s

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f NRC RAI Number . NRC lssued Date 151 Status 3.7.13 02 12/5/97 Open. Comed Action Required NRC Description ofissue 3.7.13 2 DOC M.9 L JFD Bases P.38 i CTS 3.9.4 l- CTS 4.9.4.2 I

ITS Ba 7.13 Bases. APPLICABILITY The CTS markup for CTS 4.9.4.2 changes the words "with the equipment hatch removed" to "with the equipment hatch not .

intact." While this change is considered acceptable, the justification provided in M.9 and the description provided in ITS

B3.7.13 Bases - APpLICABILI FY defining "not intact

• as including both personnel air lock doors opened is unacceptable.

CTS 3.9.4 specifies containment OPERABILITY during CORE ALTERNATIONS and movement ofirradiated fuel in containment. Under these conditior.s CTS 3.9.4 requires that the personnel hatch (air lock) and the personnel emergency -

exit hatch (air lock) have at least one door closed. CTS 4,9.4.2 whlch verifies that the FilB Ventilation System can maintain a negative pressurrs in the fuel building with the equipment hatch removed (not intact) would require this SR be performed under the conditions of the CTS 3.9,4, that is the air locks closed by a minimum of one door, The proposed definition of not intact (both air lock doors open) is not in accordance with current licencing basis as described in CTS 3/4.9.4, and would require a NRC technical staff review of this change. 'This would constitute a beyond scope of review item for this conversion. Comment: Delete from the definition of equipment hatch not intact the words describing both personnel air lock doors open from M.9 and ITS B3.7.13 Bases APPLICABILITY.

Comed Response to issue

. DOC 3.7 M9 will be revised to include the following justification. "The proposed change is bounded by the CTS allowance which permits core alterations or movement ofirradiated fuel with the equipment hatch removed. This allowance is contingent upon the FilB Ventilation System's ability to maintain a negative pressure in the fuel building. Because the airlock is contained within the equipment hatch, the release pathway to the FilB is much smaller and restoration to an intact condition is much easier ead quicker to attain than reinstalling the equipment hatch. This change poses less of a relaxation than that which is currently permitted. This change is not applicable to the emergency hatch since it provides a direct pathway to the environment without the charcoal filtration available vir, the FIO Ventilation System; This change will be ;

provi3cd in'our comprehensive ITS Section 3.7 closcout submittal re.ision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

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51 I

Response b NRC RAI Dated 12/05/97 os-reb 9s l ~55tC RAI Number NRC issued Date RAI Status b 3.7,13 03

, Ai ,) 12/5/97 Open Comed Action Required NRC Description of issue 3.7.13 3 DOC M.12 I, JFD II.18 JFD P,16 JFD Ilases P.38 5 CTS 4.9.4.2 CTS 4.9.12.d.3)

ITS SR 3,7.13.3 and Associated Bases -

ITS SR 3.7.13.5 and Associated Ilases

'_ . Justification M.12 states the following: "ITS SR 3,7.13.5 adds a Cow rate requirement to CTS 4.9.12.d.3). This SR verifies

- the ability of the FilB Ventilation System to maintain the fuel building at a negative pressure, if the system were to run at a flow rate greater than design, the negative pressure may be met, but the larger How rate could be indicative of system degradation." CTS 4.9.4.2 and ITS SR 3.7.13.3 perform the same test, but the enclosure now is the fuel building and

- containment. No now rate requirement is included in ITS SR 3.7.13.3. Based on M.12 above, a Cow rate requirement should also be provided for ITS SR 3.7.13.3, Comment: Revise ITS SR 3.7.13.3 to include a Dow rate requirement or

_ provide a discussion and justification based on system design or operational constraints to show that a now rate requirement is not needed in this case.

Comed Response to Issue -

No change. Increased now alone would not indicate system malfunction. The system is equipped with flow control dampers and Dow through the plenum is verified by existing surveillances. The flow to/from containment is small in comparison to the FilB exhaust flow Design flow for the FilB exhaust is near 21,000 cfm while the Containment Mini- -

' Purge Supply and Exhaust fans are designed for 3,000 cfm. Considering that only a small portion of this now would be

-/ available for " leakage" to the Filll, the total flow from the FilB would remain essentially unchanged, and would remain .

plus or minus 10% of design now allowed by ANSI test methods. Comed continues to pursue this change.

l k

l

Response tb NRC RAI D ted 12/05/97 05-Fch-98 NRC RAI Number NRC Issued Date RAI Status 3.7.13 04 12/5/97 Open-Comed Action Required NRC Description ofissue 3.7,13 4 - - DOC L.16 CTS 3.9.4 ACTIONS CTS 3,9.12 ACTIONS ITS 3.7.13 ACTIONS The CTS markup of CTS 3.9.4 ACTIONS adds ITS ACTIONS A, B, and C, and classines this modi 0 cation as a Less Restrictive change (L.16). While the addition ofITS ACTION A is considered to be a Less Restrictive change, the .

additions ofITS ACTIONS 11 and C are considered as an administrative change. Since the CTS requires cascading, the in operability of the FilB Ventilation System for CTS 3.9.4 would require entry into CTS 3.9.12 ACTIONS w hich are ITS ACTIONS 11 and C. Comment: Revise the markup for CTS 3.9.4 ACTIONS to show that ITS ACTIONS B and C are administrative changes rather than Less Restrictive changes. Provide additional discussion andjustifications for this -

Administrative change.

Comed Response to Issue ComFd will revise the DOC for Insert 3.9 4 A which added Conditions B and C from 3.7-Ll6 to an 'N designator, thereby ,

identifying ITS Conditions Il and C as administrative changes. This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

The inoperability of the FilB Ventilation System would require entry into CTS LCO 3.9.12, not CTS LCO 3.9.4. CTS LCO 3.9,4 provides an allowance which is contingent em the proper functioning of the Fila Ventilation System, flowever, with the FilB Ventilation System inoperable, the : 0 statement of CTS LCO 3.9.4 can still be met by maintaining the equipment hatch in place. Therefore, multiple LCv ~ ;re inappropriate. Comed continues to pursue this change.

(See RAI 3.7.7 03 and RAI 3.7.8 05.)

R NRC RAI Number NRC Issued Date RAI Status

_ (] - 3.7.13-05 12/5/97 Open- NRC Action Required NRC Description of Issue 3.7.13 JFD C.2 JFD Bases C.3 CTS 3.9.12 ACTON c STS 3.7,13 ACTIONS 113 3.7.13 ACTIONS Note and Associated Bases n

TSTF-36 Revision 2 modifies STS 3.7.12 ACTIONS by adding a Note which states that "LCO 3.0.3 is not applicable." The staff has not yet reviewed and approved TSTF 36, but will recommend that this change be modified to locate the Note above STS 3.7.13 RA C.I and RA D.I to be consistent with the Standby Gas Treaunent System STS b BWR/4 (NUREG 1433) and BWR/6 (NUREG 1434), and as being the snore appropriate place for this Note. Comment: Revise the CTS /ITS markups to reflect this proposed change to TSTF-36 and provide additionaljustification and discussion for this change.

Comed Response to issue No change. Comed is currently pursuing this change as TSTF 36, Rev. 2 which is currently being reviewed by the NRC. If rejected by the NRC on a generic basis, Comed will continue to pursue the same change on a plant specific basis.

OO 53

r Response to NRC RAi Dzted 12/05/97 05-Feb-9s

~NRC RAI Number NRC ligued Date RAI Status

- 3.7.13 06 12/5/97 Open NRC Action Required NRC Description ofIssue 3.7.136 JFD C.9 STS 3.7.13 apt'LICAlllLITY ITS 3.7.13 APPLICAlllLITY t

ITS 3.7.13 APPLICABILITY modifies STS 3.7.13 APPLICAlllLITY in accordance w.th WOG-81. See item Number 3.7.10 3. Comment: See !!cm Nuuber 3.7.10-3.

Comed Response to issue WOG-81 will be withdrawn in its entirety throughout the ITS submittal. The submittal will be revised to adopt the STS-presentation in the Applicability Section. This change will be provided in our comprehensive ITS Section 3.7 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl. (See RAls 3.7,10-03, RAI 3.7.11 02,3.9.4-06, and 3.9.7 05.) .

NRC RAI Number NRC lssued Date RAI Status 3.7.14 01 12/5/97 Open-NRC Action Required NRC Description of Issue 3.7.14 1 DOC A.26 JFD P.4 JFD Bases C.9 JFD ilases P.31 CTS 3/4.9.11 ITS 3.7.14 Ily letter dated November 5,1996, ComFd Requested a change to CTS LCO 3.9.11, CTS 5.6.1.1 and CTS 6.9.1.10. CTS 3/4.9.11 was . narked up to reflect this 11/5/96 request. This request has been approved by the staff, but is only a temporary change which expires in December,1997. The permanent TS changes have been submitted for staff review and approval in an amendment change package dated June 30,1997. Thus, the changes associated with this specification and their acceptance is a beyond scope of review item for this conversion. Comment: The review of the conversion of CTS 3/4.9.11 to ITS 3.7.14 is delayed pending staff's approval of the licensee's 6/30/97 TS change request and resubmittal by the licensee of the CTS /lTS markups for ITS 3.7.14, Comed Response to issue 2/6/98 Corrected Response: By T. Tulon (Commonwealth Edison) to United States Nuclear Regr!atory Commission (Document Control Desk) letter dated October 10,1997, Comed supplemented the original ITS submittal with ITS Revision B. ITS Revision B contained the ITS versions of the CTS license amendment requests for 1)the Non Accessible Area Exhaust Filter Plenum and the Fuel llandling Building Ventilation Systems, and 2) Boron Credit in the Spent Fuel Pool. NRC letter dated April 2,1997 issued Amendment 86 for Byron and Amendment 78 for Braidwood for soluble boron in the spent fuel pool (SFP). Since the license amendments were temporary in nature, ComSd letter dated June 30,1997 proposed changes to permanently take credit for soluble boron in the SFP Additionally, Comed responded to the NRC's request for additional information in Comed letter dated September 25,1997. Comed used the June 30,199.7 and the September 25,1997 submittal revisions as the CTS markup pages for ITS Revision B. Ilowever, a recent Safety Evaluation Report (SER)issucd December 4,1997 approved Amendment 94 for Byron and Amendment 86 for Braidwood for Boron Credit in the Spent Fuel Pool. The changes contained in ITS Revision B were approved in the SER for the Current Technical Specification amendments for Byron and Braidwood, if there are any question after the Staff reviews the CTS SER for Boron Credit in the Spent Fuel Pool and ITS Revision II, Comed will address them at that time. (See RAI 1.7.15-01 and RAI 3.7.16-01.)

v 54 I

1

l Resporse to NRC RAI Dat:d 12/05/97 05 rebA s NRC RAI Number NRC issued liste RAI Status 3.7.15-01 ,12/5/97 Open.NRC Action Required NRC Description ofissue 3.7.15 1 DOC A.26 JFD P.4 1 JFD Bases C.9 JFD Bases P.31 CTS 3/4.9.11 ITS 3.7.15 3

See item Number 3.7.141. Comment: The review of the conversion of CTS 3/4.9.11 to ITS 3.7.15 is delayed pending staffs approval of the licensee's 6/30/97 TS change request and resubmittal by the licensee of the CTS /ITS markups for ITS 3.7.15.

Comed Response to issue 2/6/98 Corrected Response: See Comed Response to RAI 3.7.14-01. If there are any question aRer the Staff reviews the CTS SER for Boron Credit in the Spent Fuel Pool and ITS Revision B, Comed will address them at t'.at time.

- NRC RAI Number NRC Issued Date RAI Status 3.7,16-01 12/5/97 Open NRC Action Required NRC Description ofissue 3.7.16 1 JFD P 4 JFD Bases C.9 .

JFD Bases P.31

- ITS 3.7,16 The CTS markup does not show anything for ITS 3.7.16. Thejustifications provided in the ITS markup are P.4 and Bases P.31, Resolution of ITS 3.7.16 will depend on the resolutions ofitem Numbers 3.7.14 1 and 3.7.15 1. Comment: The review of the ITS 3.7.16 is delayed pending staffs approval of the licensee's 6/30/97 TS change request and resubmittal by the licensee of the ITS markup ofITS 3.7.16.

Comed Response to Issue 2/6/98 Corrected Response: See Comed Response to RAI 3.7.14-01; if there are any question after the Staff reviews the

- CTS SER for Boron Credit in the Spent Fuel Pool and ITS Revision B, Comed will address them at that time.

NRC RAI Number NRC Issued Date RAI Status 3.7.17-01 12/5/97 Open- NRC Action Required

' NRC Description ofissue -

3,7.17 1- JFD Bases P.20 ITS B3.7.17 Bases - BACKGROUND The third paragraph, first sentence, references the primary coolant specific activity limits of LCO 3.4.16. The stating of the I microcurie per gram limit has been omitted because the limit is different between Braidwaod and Byron. This is a legitimate difference and its should be stated clearly rather than disguised by this alternative editorial wording. Comment:

Revise the Bases to include the specific activity valves for each facility.

Comed Response to issue Comed will revise the Bases to reflect the specific activity values for Braidwood and Byron. The submittal will be revised

- to adopt the STS presentation in the Applicability Section. This change will be provided in our comprehensive ITS Section

(~- 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAI.

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55

Respo:se ta NRC RAI D:ted 12/05/97' ns-reh-9s

~ NRC RAI Number NRC lisued Date RAI Status 3/4.7.8-01 12/5/97. Open.NRC Action Required NRC Description ofissue 3/4.7.8 1 DOC LA.39

. CTS 3/4.7.8 CTS 3/4.7.8 is being totally relocated out of the TS to the TRM, The justi0 cation used for this is LA.39. The LA justi0 cations are to be used to relocate specl0c requirements and detailed information from individual specifications. The relocation of entire speci0 cations such as 3/4.7.8 are to be justified using the Relocated (R.x) designation. Comment:

Revise the CTS markup to show that this change is a relocated item and provide the appropriate discussion and justi0 cation for this relocated CTS.

Comed Response to issue The Braidwoo& Byron ITS Summary Disposition Matrix of the Split Report for CTS LCO 3.7.8, " Snubbers" will be revised to show CTS LCO 3.7.8 as being " relocated" and Note 22 will be deleted. In addition, DOC 3.7 LA39 will be changed to an 'R' designator, This change will be provided in our comprehensive ITS Section 3.7 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.7 RAl.

NRC RAI Number - NRC Issued Date RAI Status 3.9-01 12/5/97 Open NRC Action Required

! NRC Description ofissue 1 3.9-01 DOC LA6 CTS 3/4.9,3, Decay Time q

t Byron /Braidwood characterized this change as less restrictive generic, LA. His speci0 cation is relocated based on application of the 10 CFR 50.36. Comment: Revise the LA.6 DOC to a Relocated DOC.

' Comed Response to issue

- No change. 'LA' designators are used for relocating details o' specifications or specifications that are not addressed by the generic WOG Split Report. LA6 states, "This requirement is to be relocated to the TRM." Although CTS LCO 3.9.3,

" Decay Time," satisfies Criterion 2 of the Technical Speci0 cation Selection Criteria in 10 CFR 50.36(c)(2)(ii), it is not classified as an 'R' designator because it is not identified in the Generic WOG Split Report as being relocated. This presentation is standard throughout the Byron /Braidwood submittal. Comed conttaues to pursue this change.

56

Response to NRC RAI Dat:d 12/05/97- Os rab-9s

'NRC RAI Number NRC losued Date RAI Status 3,9-02 12/5/97-- Open NRC Action Required NRC Ikseriptka ofissue

~ 3.9 02 . - See table below

-_ Proposed changes based on STS generic changes that are still pending or that have been rejected, as indicated in the table, should be withdrawn. Either adopt the STS or maintain the CTS requirements.

Byron /Braidwood Units I and 2 "Beyond Contractor Review Scope (BCRS)" Table Section 3.9, Refueling Operations Updated: November 25,1997

--ITS Section or ITS LCO JrD Reasons for Exemption of Review Comment (if required) 1 2 3 4 5 6 7 3.9.7 C3 BC1 - X -- - - - - TSTF 20 y 11/24/97 status: pending 3.9.6 L11 Cl P4

-BC2. --

BP24 - X - - - - - TSTF-21 proposed RI

- l 1/24/97 status: TSTF-21 approved on 5/19/97, but Rev 1 is not to staff for review.

3.9.5 C2 -

= 3.9.6 LA10. X .- - - - - TSTF 22 11/24/97 status: Reject [] if CTS contains flow rates B3.9.3 - BC5 BP4 - 'X - - - - -

TSTF 23 RI 11/24/97 status: rejected 11/19/97 by TSTF, Rev3 is pending issuance for staff review, Rev2 is being reviewed by the staff.

3.9.3 C5 BC4-- X - . - - - TSTF-96 11.24.97 status: approved 10/28/97 3.9 C4 - X -- - - - -

WOG-81 11/24/97 status: WOG # not under review.

B3.9- DC3- X - - - - - Editorial 1 1!/24/97 status: Approved 10/18/95

' 3.9.4 M8 P3 - -- -

X - - -

- 3.9.1 ... P1 - -- - - -

X --

Editorial.11 11/24/97 status: Approved 4/l1/97

( Reasons for exempting change from review:

- 1. Cover letter 12 13-96, Attachment #3 Existing and Future Licensing Amendments to be incorporated into ITS.

57

Response to NRC RAI liated 12/05/97 Os-rch-98 h

C er letter 12 1386',ittachminii4 Fending and Proposed ISTS fhhe~frAe'lers G 3.

4.

5.

Comed letter 2-24-97, Attachment #1, Generic Changes versus CTS DOCS Cover letter 1213-96, Attachment #5 Beyond Scope Change (changes that are different than both CTS and ITS).

Cover letter 1213-96, Attachment #6 Beyond Scope Bracketed Changes 6CemEd letter 2-24-97, Attachment #2, Plant Specine Change Justi0 cations Which are Now in the Generic STS Change Process

7. Other Reason as identined in comments to this table and with the written prior approval of the NRC Technical Monitor as referenced.

Comed Response to issue Regarding TSTF 20. TSTF-96, Editorial-1, and Editorial-ll: No change based on NRC approval of these changes.

Regarding WOG 81: Withdrawn. See RAls 3.7.10-03, RAI 3.7.11-02,3.7.13-06,3.9.4-06, and 3.9.7-05. Regarding TSTF-22: Withdrawr.. See RAls 3.9.5-05 and 3.9.6-04. Regarding TSTF 23: See RAI 3.9.3-01. Regarding TSTF-2): No change. LCO 3.9.6 requires two RilR loops to be OPERABLE and onc RilR loop to be in operation. The LCO Section of the Bases for ITS LCO 3.9.6 states that the now path starts in one of the RCS hot legs and is returned to the RCS cold legs.

3 With the RilR System aligned to, or during transitioning to or from, the Refu: ling Water Storage Tank (RWST) to support filling or draining the refueling cavity, or to support required testing, the LCO would be considered not met, in order to acknowledge these operational conditions, TSTF-21, Revision I (NRC approved), made a change to the Bases for LCO 3.9.6 to allow both RHR pumps to be aligned to the RWST to support tilling or drainicg the refueling cavity, or to support required testing. Comed disagrees with this change which allows an exception to the LCO to be included in the Bases with no corresponding LCO change. Instead, Comed adJed a Note to the LCO that permits the required RllR loop to be remosed from operation and considered OPERABLE w hen aligned to, or during transitioning to or trom, the RWST te support filling or draining the refueling cavity, or to support required testing, if capable of being realigned to the RCS.

ComLd contends that without this change, the LCO would he considered not met when the RilR System is aligned to the RWST, and Condition A would have to be entered. The Required Action requires immediately initiating action to restore the RilR loops to OPERABLE status, thereby prohibiting the use of the RHR System to 011 or drain the cavity or perform required testing. Comed continues to pursue the change as addressed by LCO JFDs 3 9-Cl and 3.9-P4 and Bases JFDs 3.9-C2 and 3.9-P24.

NRC RAI Number NRC lssued Date RAI Status 3.9.1-01 12/5/97 Open - NRC Action Required NRC Description of Issue 3.9.l-01 Bases discussion for ITS 3.9,1 Applicable Safety Analyses, page B 3.9-2 In the second paragraph of the Applicable Safety Analyses, it has been proposed to delete the term " margin of safety" and replace it with the denned term " Shutdown Margin", The Shutdown Margin deOnition addresses stuck rod worth which is not relevant during refueling operations. Comment: This is not ajustinable plant specine or editorial difference. Revise the submittal to conform to me STS.

Comed Response to issue Comed will conform to the STS. This change will be provided in our comprehensive ITS Section 3.9 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAI.

O

Responsa to NRC RAI D:ted 12/05/97 Os-Feb-9s

~ RC RAI Number NRC Issued Date RAI Status 3.9.1 02 12/5/97 Open-NRC Action Required NRC Description ofissue 3.9.1-02 Bases discussion for ITS 3.9.1 Actions, page B 3.9 3 ne first sentence of the first paragraph of the Actions section of the STS has not been adopted in the ITS. This sentence states, " Continuation of Core Alterations or positive reactivity additions (including actions to reduce boron concentration) is contingent upon maintaining the unit in compliance with the LCO." Comment: This is not a justinable pisnt sp:cific or editorial difference. Revise the submittal to conform to the STS.

I Comed Response to Issue he sentence in the Actions Section of the Bases for NUREG LCO 3.9.1," Continuation of CORE ALTERATIONS or positive reactivity additions (including actions to reduce boron concentration) is contingent upon maintaining the unit in compliance with the LCO" will be retained. This change will be provided in our comprehensive ITS Section 3.9 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAI.

NRC RAI Number NRC issued Date RAI Status 3.9.1-03 12/5/97 Open - NRC Action Pcquired

- NRC Description of issue 3.9.1-03 Bases discussion for ITS 3,9.1 Actions, page B 3.9-3 in the middle of the first paragraph of the Actions section of the STS the term "all operations involving" has not been adopted in the ITS. Instead, an insert has been proposed that states, "an inadvertent criticality may occur due to an incorrect fuel loading. To minimize the potential of an inadvertent criticality resulting from a loading error," This appears to q overlook the possibility of an inadvertent criticality as a result of a reduced boron concentration Comment: This is not a justinable plant specific or editorial difference. Revise the submittal to conform to the STS.

Comed Response to Issue No change Comed disagrees. The possibility of an inadvertent criticality as a result of a reduced boron concentration is still addressed in that same sentence by " . . and positive reactivity additions must be suspended immediately." Replacing "all operations involving CORE ALTERATIONS" with " CORE ALTERATIONS" does not address a reduction in boron concentration in either case. Comed continues to pursue this change.

NRC RAI Number NRC Issued Date RAI Status 3.9.1 04 12/5/97 Open - NRC Action Required

~

NRC Description ofIssue 3.9.1 04 Bases discussion for ITS 3.9.1 Actions, page B 3.9-3 An insert has been added to the end of the second paragraph of the Actions section. The intention of the insert is to exclude

" normal heatup/cooldown of the coolant volume for the purpose of system temperature control" from Required Action A.2 to suspend positive reactivity additions. Comment: This is not ajustifiable plant specific or editorial difference. Revise the submittal to conform to the STS. This issue should be brought to the Tech Spec Task Force for future action.

Comed Response to issue -

The change associated with Bases JFD 3.9-Pl4 has been presented to the WOG for generic change consideration and a traveler is being created for the other Owner's Groups' review and approval. Comed continues to pursue this change plant specifically until generic resolution has been achieved.

C

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59

Respo:se to NRC RAI Dated 12/05/97 Os r:b-9s

- NRC RAI Number NRC lssued Date RAI Status 3.9.1 05 12/5/97 Open NRC Action Required

- d NRC Description ofIssue 3.9.1 05 Hases discussion for ITS SR 3.9.1.1, page 113.9-4 in the STS, the last sentence of the first paragraph states,"The boron concentration of the coolant in each volume is deiermined periodically by chemical analysis." The ITS has not adopted the term "in each volume", Comment: This is not a justillable plant specific or editorial difference. Revise the submittal to conform to the STS.

Comed Response to issue No change. Since the LCO is applicable only to the Olled portions of the RCS, the refueling canal, and the refueling cavity that are hydraulically coupled to the ieaetor core, the boron concentration limit is applicable only for the reactor core or those areas in direct communication with the reactor core (see llases JFD 3.9-P7). Derefore, in the Surveillance Requirements Section of the Bases for NUREO LCO 3.9.1, the phrase, "in each volume" is technically incorrect if the RCS, the refueling canal, and the refueling cavity were not hydraulically coupled. Comed believes this chan; e is necessary for properly representing the requirements of the LCO and SR 3.9.1.1, and continues to pursue this change NRC RAI Number NRC issued Date RAI Status 3.9.1-06 12/5/97 - Open NRC Action Required NRC Description ofIssue 3.9.1-06 DOC A9 CTS 3.9.1 L The ITS adds the refueling cavity to the list of speciGed volumes that require the boron concentration limits of TS to be l .

met. Comment: Based on the discussion provided in A9 the change is not justifiable as an administrative change. Provide g] additionaljustification to support the administrative change category.

Comed Response to issue h

DOC 3.9 A9 will b revised to state, " CTS LCO 3.9.1 requires maintaining boron concentration of all filled portions of the RCS and refueling canal. Clearly, it is the intent of CTS to include the refueling cavity when referencing the RCS in the LCO and Surveillance Requirements Sections. Therefore, ITS LCO 3,9.1 clarines the " filled portions of the RCS" region by specincally denoting the " refueling cavity" area. This change is perceived as the intent of the CTS wording is considered editorial in nature and does not involve a technical change (either actual or interpretational) to the TS. This change is consistent with NUREG 1431." T'ils change will be provided in our comprehensive ITS Section 3.9 closcout submhtal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAl.

NRC RAI Number NRC lssued Date RAI Status 3.9.1 07 12/5/97 Open NRC Action Required NRC Description ofissue 3.9.1 07 DOC LAI CTS 3.9.1 The CTS markup shows the application of the LAI DOC to LCO 3.9.1.b(2) which is note " that is deleted by DOC A3.

Comment: Revise th; CTS markup to correct the applications of LAI and A3.

Comed Response to issue ComFd disagrees. In the CTS Markups, the 'LAl' designator pertains to CTS LCO 3.9.1.b.2, excluding the foomote symbol

("). The 'A3' designator addresses the footnote symbol in the LCO and footnote ". Comed continues to pursue this change.

a 60 i

Response ta NRC RAI D:ted 12/05/97 05-reh-9s

~NRC RAI Number . NRC Issued Date RAI Status 3.9.1 08 12/5/97 Open - NRC Action Required J NRC Descr!ption of issue 3.9.1 08 JFD Pl CTS LCO 3.9.)

The Pl DOC adds the article "the" to SR 3.9.l.1, Comment: Revise ITS SR 3.9.1.1 to adopt the STS. (This and other sentence structure changes could be made throughout the STS and the industry declined to adopt and English" language format in favor of specifications that contained the required information with a " human factored" format.

Comed Response to Issue No cht. age. This change has been approved on 4/l1/97 as Editorial 11. (See RAI 3.9-02.)

NRC RAI Number NRC lssued Date RAI Stat c 3.9.2-01 12/5/97 Open - NRC Action i quired

- NRC Description ofissue 3.9.2-01 ITS 3.9.2 Actions Note ITS 3.9.2 contains an Actions Note which states,

• Separate Condition entry is allowed for each unborated water source isolation valve." Comment: The rubmittal has neither discussed norju tined using this note. Revise the submittal to provide thejustification for this note.

ComF.d Response to Issue fg No change. Comed disagrees. The CTS Markup for CTS SR 4.9.l.3 addresses the addition of the ITS LCO 3.9.2 Actions i

Note with 'A 10' and 'M I' designators (page 3/4 9 1). Comed continues to pursue this change, i

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l NRC RAI Number NRC issued Date RAI Status 3.9.2-02 12/5/97 Open-NRC Action Required NRC Description ofissue 3.9.2-02 Bases discussion for ITS 3.9.2 LCO, page B 3.9 5 The proposed insert for this section reads,"This LCO includes valves from the RWST whenever concentration of the RWST falls below specined limits. Acceptable isolation in the closed position of unborated water source isolation valves is provided by mechanical stops, removal of air, or removal of electrical power." The revision that follows is a proposed alternate. "This LCO includes valves associated with the RWST whenever the boron concentration of the RWST falls below speci0ed limits. The unborated water source isolation valves are acceptably secured in the closed position by utilizing mechanical stops, removing air, or removing electrical power as appropriate." Comment: Revise the submittal to incorporate the recommended insert material.

Comed Response to issue No char.ge. In comparing Comed's proposed Bases statement and the reviewer's proposed statement the only changes are wording preferences which are strictly editorial. Since there is no technical or operational benents gained in using the proposed wording. Comed elects to maintain our current wording, and continues to pursue this change.

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i Respo:se to NRC RAI D ted 12/05/97 05-Feb-9d i- _

{ ' NRC RAI Number NRC issued Date RAI Status O 3.9.2-03 12/5/97 V NRC Description ofissue Open NRC Action Required 3.9.2-03 Bases discussion for ITS SR 3.9.2.1, page B 3.9-7 in the STS the Orst three sentences of the Bases d!.,cussion for SR 3.9.2.1 provide general backgrouno about the surveillance. This material has not been adopted in the Bases discussion for corresponding ITS 3.9.2. Comment: This is not a justinable plant specific or editorial difference. Revise the submittal to conform to the STS.

Comed Response to issue Comed will revise the submittal to edopt the Orst three sentences in the Surveillance Requirements Section of the Bases for SR 3.9.2.1. - This change will be provided in our comprehensive ITS Section 3.9 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAl.

NRC RAI Number -- NRC issued Date RAI Status 3,9.3 01 12/5/97 Open NRC Action Required NRC Description of issue 3.9.3 01 DOC LIO CTS 3/4.9.2 CTS 3/4.9.2 establishes the requirements for the nuclear instrumentation in Mode 6. The LCO requires in part audible indication in the containment and the control room. it hes been proposed to delete this requirement because there is no design requirement for the audible alarm and the ITS requirement to isolate all unborated watet sources in Mode 6 (ITS 3,9.2) provides adequate assurance that a reactivity event will not occur. Comment: Insuf0cientjusti0 cation has been q provided to support this proposed change, Revise the submittal to move this requirement to the ITS Bases, consistent with Q '

NUREG 1431,

' Comed Response to issue No change. Deleting the audible alarm requirement from the Background Section of the Bases for LCO 3.9.3 is consistent -

with TSTF 23 Revision i and Revision 2 (both under NRC consideration). For plants such as Byron and Braidwood,

'which isolate all baron dilution paths per LCO 3.9.2, the source range OPERABILITY requirements include only the visual monitoring function. Braidwood and Byron UFSAR Section 15.4 provides the following discussion for boron dilution during MODE 6: "An uncontrolled boron dilution transient cannot occur during this mode of operation, inadvertent dilution is prevented by administrative controls which isolate the RCS from the potential source of unborated water, CVCS valves, specined in CTS 3.9.1 (ITS 3.9.2.1) will be veri 0ed closed and secured in position by mechanical stops or by removal of air or electrical power. These valves block all flow paths that could allow unboiated makeup water to reach the RCS. Any makeup which is required during refueling will be borated water supplied from the RWST by the low head injection pumps." This method of valve isolation is acceptable by the NRC as presented in other ITSs involving isolation of valves.' Based on the above justincation, audible alarms are not required.- Comed continues to pursue this change.

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R;sponse ta NRC RAI D:ted 12/05/97 Os reb-98

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h NRC RAI Number NRC issued Date RAI Status

( 3.9.3 02 12/5/97- Open . NRC Action Required NRC Description ofIssue 3.9.3 11 ass discussion for ITS SR 3.9.3.2, page B 3.910 I

The STS 11ases states that the reason that the Channel Calibration is performed with an 18 month frequency is that this surveillance needs to be performed under the conditions that apply during a plant outage. This information has not been adopted in the ITS. Comment: This is not a justifiable plant specific or editorial difference. Revise the submittal to 4 confonn to the STS.

Comed Response to issue Comed will conform to the STS. This change will be provided in our comprehensive ITS Section 3.9 closeout submittal revision upon NRC's concurrence with the Comed Responses a the ITS Section 3.9 RAl.

NRC RAI Number NRC Issued Date RAI Status 3.9.4 01' 12/5/97 Open - NRC Action Required NRC Description ofIssue 3.9.4-0i DOC A6 JFD P2 CTS 3,9.4.a ITS LCO 3.9.4 Note CTS LCO 3.9.4.a allows removal of the equipment hatch pursuant to the successful performance of the Surveillance Requirement to verify the Operability of the fuel handling building exhaust plenums. This has been reformatted in the form of an LCO note for corresponding ITS 3.9.4. This note states that item a of the LCO is only required when the Fuel y llandling Building Exhaust Filter Plenum Ventilation Systera is not in compliance with ITS LCO 3.7,13. Ilowever, the Applicability for ITS 3.9.4 and ITS 3.7.13 are not the same, ne note should be revised to state that item a of the LCO is only required when the Fuel llandling Building Exhaust Filter Plenum Ventilation System is not Operable. Comment:

Revise the submittal to specify system Operability status rather than compliance with LCO 3.7.13.

Comed Response to issue No change. The proposed wording for the LCO 3.9.4 Note stating, " . . Sy, tem is not Operable" merely repres nts a wording preference over Comed's proposed wording stating, " ... System is not in compliance with LCO 3.7.13, .. ."

Comed continues to pursue this change.

NRC RAI Number NRC issued Date RAI Status -

3.9.4-02 12/5/97 Open - NRC Action Required NRC Description ofIssue 3.9.4-02 JFD Pl7 Bases discussion for ITS SR 3.9.4.2, pag,e B 3.9 15 in the STS the lest part of the paragraph describes other Surveillance Requirements in other LCOs that demonstrate the Operability of the containment purge valves and their associated actuation instrumentation. This information has not been adopted in the iTS. Comi 't: This is not ajustifiable plant specific or editorial difTerence. Revise the submittal to conform to the STS.

Comed Response to Issue Comed will conform to the STS. This change will be provided in our comprehensive ITS Section 3.9 closeout submittal revision upon NPC's conct rence with the Comed Responses to the ITS Section 3.9 RAI.

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Response (ShRC RAI Dated 12/05/97 Os-reb-9s

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NRC RAI Number NRC Issued Date RAI Status 3.9.4-03 12/5/97 Open. NRC Action Required NRC Description ofissue 3.9.4-03 IX)C L2 CTS 4.9.4.1 CTS 4.9.9 DOC L2 states the CTS has been revised to relax the surveillance frequency from 7 days to 18 months. Comment: DOC L.2 jmtifies the proposed changes to CTS 4.9.9 test frequencies; however, DOC L.2 does not provide appropriate discussion for CTS 4.9.4.1 changes identified as L2 and the CTS 4.9.4.1 markup does not reflect the proposed ITS. Revise the CTS markup and provide DOC discussion to address each proposed CTS change.

Comed Response to issue CTS DOC 3.9-L2 will be revised as follows, " CTS SR 4,9.4.1 and SR 4.9.9 require the containment purge isolation valves to be demonstrated OPERABLE every 7 days by verifying that containment isolation occurs on an actuation signal.- ITS SR 3.9.4.2 requires the containment purge isolation valvea to be demonstrated OPERABLE every 18 months by verifying that containment isolation occurs on an actuation signal. CTS SR 4.9.4.1.b has been revised to relax the Surveillance Frequency from 7 days to 18 months. This is acceptable since the. containment purge isolation system requires the performance of additional SRs to ensure operability of the system and the containment isolation function. The ia month Frequency maintains consistency with other similar ESFAS instrumentation ano valve testing requirements. The SRs for the actuating instrumentation are contained in LCO 3.3.6. These requirements include a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Channel Check, a 92 day Channel i

Operational Test, and an 18 month Channel Calibration and TADOT (for the Manual Initiation function only). In addition to the instrumentation requirements of LCO 3.3.6, each containment > urge isolation valve requires the verification of the isolation time in accordance with the IST program (SR 3.9.4.3). In addition, CTS SR 4.9.4.1.a requires verifying that the penetrations are in their closed' isolated condition, while ITS SR 3.9.4.1 demonstrates that the open purge valves are not blocked from closing and each valve operator has motive power by verifying each required penetration is in the required hd state. These changes are consistent with NUREG 1431 " This change will be provided in our comprehensive ITS Section 3.9 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAI.

NRC RAI Number NRC issued Date RAI Status 3.9.4-04 12/5/97 Open-NRC Action Required NRC Description ofissue 3.9.4-04 DOC M8 JFD p3 ITS SR 4.9.4.3 DOC M8 justifies adding purge valve isolation time testing in accordance with 1:A frequencies. Comment: The proposed SR represents a generic change to the STS. Typically, valve isolation testing is performed as part of the system operability requirements. Explain why this proposed SR does not duplicate the testing requirements of ITS SR 3.6.3.5.

Comed Response to issue No change. ITS SR is applicable in MODES 1-4. ITS SR 3.9.4.3 is applicable during CORE ALTERATIONS and during movement ofirradiated fuel assemblies within containment. Therefore, they are not duplicate testing requirements. Comed continues to pursue this change, 64

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NHC Descriptkm ofissue i 3.9.4 05 DOC Ai1 ITS LCO 3.9.4 DOC A 11 states that the requirements of CTS 3.9.9, " Containment Purge Isolation System" are retained in the presentation ofITS LCO 3.9.4.c which requires an operable Containment tvge Isolation System. Comment: The proposed ITS LCO 3.9.4.c requires the " Containment Ventilation (emphasis adde 6s System to be operable. Provide a DOC for ti,e deletion of Containment purge isolation System operability requirements during core alterations or movement of irradiated fuel in contalmaent. I a

ComF.d Respase to Instae No change. Containment

• Purge Isolation" System and Containment " Ventilation" System are one and the same 'lhey are/can be used interchangeably. Comed continues to pursue this change.

NHC RAI Number NHC losued Date RAI Status

3.9.4 06 12/$/97 Open NRC Action Required

NHC Description ofissue i 3.9.4 06 Ji'D C4

ils 3 9 4 Applicability JI D C4 proposes to revise the STS format for constructing applicable conditions. Comment

This is a generic change that requites a stalT approved TSTF changt. Revise the submittal to adopt the STS.

( Comed Response to issue WOG Ri will be withdrawn from the ITS submittal. ITS and NUREG will be revised to adopt the ISTS presentation in the .

Applicability section ofITS LCOs 3.9.4 and 3.9.7, As a result, LCO JFD 3.9-C4 will be deleted. This change will be '

provided in our comprehensive ITS Section 3.9 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAL (See RAls 3.7.10 03,3.7.1102,3.7.13 06, and 3.9.7 05.)

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Response to NRC RAI D:ted 12/05/97 o$.rch-9s

~NRdWAfS5ber ~NRC lasued Date RAI Status 3.9.5 01 12/$/97 Open NRC Action Required NRC Description oflosue .

3.9.$ 01 DOC 1A CTS 3/4.9.8.1 footnote

• The footnote modines the LCO by allowing the RilR loop to be tmoved from operation during the performance of Core Alterations in the vicinity of the reactor vessel hot legs. It has been pro sed to delete the term "during the petfonnance of Core Alterations in the vicinity of the reactor vessel hot legs" from the tu Note. Comment: Insumcient justincation has been provided for this proposed change. Revise the submhtal and pro ide additionaljustl0 cation.

Comed Response to issue No change. Comed has conformed to the STS LCO 3.9.$ Note which allows the required RilR loop to be removed from

- operation for i hour per 8 hout period provided no operations are permitted that would cause reduction of the RCS baron wncentration. This Note allows other refueling operation activities such as core mapping, valve testing, installation and reinoval of temporary lighting, temporary submarines or any other activity not involving any operations that would cause a boron reduction in the RCS or a reactivity change. He CTS also provides a footnote stating that the RilR loop may be removed from operatior, for up to _1 hour per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period during the performance of CORE ALTERATIONS in the vicinity of the reactor vessel hot legs. In converting to ITS, and in compliance with the STS, the woros, "during the performance of CORE ALTERATIONS in the vicinity of the vessel hot legs" were removed. The ITS deOnition of CORE ALTERATION states,

• CORE ALTERATlON shall be the movement of any fuel, raurces, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel." The ITS dennition differs from the CTS dennition in that equipment in the vicinity of the hot leg (such as lighting, temporary submarines, etc.) is no longer required to be classined as CORE ALTERATIONS in ITS. Without the revised Note, certain operations which were allowed under the CTS Noie would i,> longer be allowed in ITS. The footnote in ITS LCO 3.9.5 is consistent with the ITS deOnition and the deletion of the words,"during the performance of CORE ALTERATIONS in the vicinity of the vessel hot leg" is appropriate Comed continues to pursue this change. (See RAI 3.9.$ 04.)

NRC RAI Number NRC losued Date RAI Status 3.9.5 02 2/5/97 Open.NRC Action Required NRC Description of issue 3.9.$ 02 Ilases discussion for ITS 3.9.$ LCO, page il 3.918

- The LCO section describes why one RilR loop must se Operable and in operation. The STS identifies removal of decay -

heat, mixing of the borated coolant to minimire the possibility of criticality, and indication of reactor coolant temperature.

De ITS has omitted mention of the indication of reactor coolant temperature. Comment

• This is not ajustifiable plant speciac or editorial change Revise the submittal to conform to the STS.

Comed Response to issue Comed will conform to the STS. This change will be provided in our comprehensive ITS Section 3.9 closcout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAl. (See RAI 3.9.6-02.)

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R:sponse to NRC RAI Dated 12/05/97 Os reb 9s NRC RAI Number NRC lisued Date RAI Status 3.9.$ 03 12/$/97 Open.NRC Action Required NHC Description of issue f

3.9.$.03 DOC M3 CTS 3/4.9.8.1 Action The C1S Action is modined in the ils to require "immediate" action to perfonn required remedial meat.ures. Comment:

- 1he DOC does not address that time limits are imposed by adoption of the STS content. provide a revised DOC. '

Comed Response to losue  !

No change. Comed disagrees < The addition of"immediately" is addrened in DOC 3.9 M3. The only time limit associated with ITS LCO 3.9.5 is the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time of Required Action A.4, which is consistent with CTS and therefore is not changed. Comed contimies to pursue this change. (See RAI 3.9,6-03.)

NRC RAI Number NRC issued Date RAlStatus 3.9.5 04 12/5/97 Open.NRC Action Required '

NRC Description of lpve l 3.9.5-04 DOC M9 1

CTS 3/4.9.8.i Note

• 1hc ITS provides allowances for removing a loop from operation. The CTS change ensures boron dilution does not occur with no h> ops in operation for the one out eight hour period permitted by the TS. Comment: Insufficient justincation has been provided to state the safety basis for this provision. Revise the submittal and provide additionaljustification.

Comed Response to lasue See Comed Response to RAI 3.9.5 01.

NRC RAI Number NRC issued Date RAI Status 3.9.5-05 12/3/9's Open NRC Action Required ,

NRC Description of issue 3.9.5-05 DOC LA10 CTS 4.9.8.1 The proposed CTS change relocates details regarding now and temperature requirements during testing to licensee controlled documen1 This is generic change TSTF 22. TSTF 22 was rejected by the stafi. Comment: Withdraw the CTS change and resubmit revised ITS.

Comed Responst :o issue Comed will revise the ITS submittal to include the now rate value in ITS SR 3,9.5,1 and ITS SR 3.9.6.l. (Note: Approved TSTF 21, Revision 1, allows delethg the now rate requirement in NUREO SR 3.9.6.L) llowever, the CTS require.nent for the RCS temperature to be less than or equal to 140 oF will be relocated to a Licensee Controlled Document. The l temperature requirement does not meet the 10CFR50.36(c)(2)(li) criteria and is not included in NUREG 1431. Relocating

! the temperature requirement (DOC 3.9 LA10) to a Licensee Controlled Document provides assurance that the requirement is maintained and any potential changes to the specine temperature requirement will require a 50.59 evaluation. DOC 3.9 LA10 will be revised to re'ocate only the RCS temperature requirement to the TRM. This change will be provided in our comprehensive ITS Section 3.9 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAl. (See RAl 3.9.6 04.)

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NRC R AI Number NRC losued Date RAIStatus 3.9.6-01 12/5'97 Open.NRC Action Required NRC llencription oflasue 3.9.6-01 Jil) P5 ITS 3.9.6 Condition A and Required Action A I Ilases discussion for ITS 3.9.6 Requited Action A.1, page 113.9 22 Condition A for STS 3.9.6 states, *Less than the required number of RilR loops Operable

• Corresponding Condition A for 11S 3.9.6 states, "One or more RilR loops inoperable." STS Required Action A.) refers to restoring the required RilR loops.115 Required Action A.1 would omit the word " required", Comment: These are not jueinable plant specluc or editorial differences. Revise the submittal to conform to the STS. These are generic changes.1hese changes should be brought to the Tech Spec Task force for future action.

Comed Response to issue No change. Comed disagrees. The NUREO rules of usage reserves the word required for when the LCO allows " options" to fulnll the TS requirement (e g., NUREO LCO 3.4.12, LTOP), or w hen the LCO requires less than the total number to be OPERAllLE. In this case, the LCO requires that two RilR loops be OPERABLE, and since there are only two RilR loops in the flyton/Iltaldwood design, adding the word " required" would be inappropriate. Comed continues to pursue this

-change.

NRC RAI Number NRC is*ued Date RAI Status 3.9.6 02 12/$/97 Open. NRC Action Required

NEC Description ofissue l 3.9.6 !!ases discussion for ITS 3.9.6 LCO, page 113.9 22 ae I CO section describes w hy one RilR loop must be in operation.1he STS states that mixing minimites the passibility of criticality and that RilR must be in operation in order to provide indication of reactor coolant temperature This material has not been adopted in the tTS, Comment

This is not ajustinable plant specine or editorial difference Revise the submittal to conform to the STS.

Comed Response to issue Comed will conform to the STS. This change will be provided in our comprehensive ITS Section 3.9 cloricout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAI. (See RAI 3.9.5 02.)

NRC RAI Number NRC lasued Date RAI Status 3.9.6-03 12/$/97 Open.NRC Action Required NRC Description of issue 3.9.6-03 DOC M3 CTS 3/4.9.8.2 Action DOC M7 1he CTS Action is modined in the ITS to require "immediate" action to perform required remedialincasures, Comment:

The DOC does not address that time limps are imposed by adoption of the STS content. Provide a revised DOC.

Comed Response to issue 2/6/98 Corrected Response: No change. Comed disagrees. T1 e addition of"immediately" is addressed in DOC 3.9 M4.

The only time limit asr clated with ITS LCO 3.9.6 is the 4 ho., Compl: tion Time of Required Action U.3, which is consistent with CTS and therefore is not changed. Comed continues to pursue this change. (See RAI 3.9.5 03.)

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NRC mal Nuw her NRC losued Date RAI Status l, 3.9.6-04 12/$/97 Open NRC Action Required f

NHC Description of lieue  ;

3.9.6 04 DOC LA10 CTS SR 4.9.8.2 1he proposed C15 change relocates details regarding now and temperature requirements during testing to licensee i controlled documents.1his is generic change TSTF.22. TSTT.22 was rejected by the stafT. Comment: Withdraw the CTS -

change and resubmit revised ITS.

Comed Response to issue  !

See Comed Response to RAl 3.9.$ 0$.

NRC RAI Number - NRC losued l> ate RAIStatus 3.9.7 01 12/$/97 Open NRC Action Required NRC I)escription of linue i 3.9.7 01 CTS 4.9.16 5 STS SR 3,9.7.1

• The CTS markup for this Surveillance Requirement refers to determining ,t tater level during the movement ofirradiated fuel assemblies. Corresponding STS SR 3.9.7.1 does not contain this applicability reference, Comment: The CTS markup ,

is in error. Revise the CTS markup to conform to the STS.

Comed Response to issue No change, Comed disagrees. The CTS markup for CTS SR 4,9.10 is merely clarifying that this surveillance is only required to be performed consistent with the revised CTS Applicability,(i.e., During movement of" irradiated fuel T assemblies ... ) asjustified in DOC 3,9 l.A11. Comed is not proposing that this Applicability reference be included in the l ITS SR. This change is consistent with the Applicability of NUREO LCO 3,9.7. Comed continues to pursue this change, NRC RAI Number NRC lasued Date RAI Status l 3.9.7 02 12/5/97 Open.NRC Action Required i NRC l>escription of issue 3.9,7 02 11ases discussion for ITS 3.9.7 Applicable Safety Analysis, page 113.9 25 l

The discussion in the STS refers to Regulatory Positions C,1.c and C.I.g of Regulatory Guide 1,25 which adopts a 23 foot minimum level requirement for tefueling. Comment: This is not ajustifiable editorial difference. Revise the submittal to either conform to the STS or provide plant specific Bases for the LCO limit of 23 feet of water above the reactor vessel Gange, Comed Restense to lisue Comed will revise the Applicable Safety Analysis Section of the Bases for ITS LCO 3.9,7 to include reference to Regulatory Guide 1.25, C,1.c and C,l.g. This change will be provided in our comprehensive ITS Section 3.9 closecut submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.9 RAl.

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Response ta NRC RAI D:ted 12/05/97 Os rsb 9s

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NRC RAI Number NHC lisued Date RAI Status 3.9.7 03 12/$/97 Open.NRC Action Required NRC Description of lasue 3.9.7-03 DOC L$

11 S LCO 3.9.7 The CTS changes identined as 15 include administrative changes because CTS limits on movement of control rods is included in the ITS dennition of CORE ALTERATIONS. Comment: Provide a separate identincation and discussion of each administrative change.

Comed Response to lasue 2/6/98 Corrected Response: No change. Comed believes that DOC 3.9 L$ adequatelyjustifies the less restrictive change, and does not contain any administrative changes. Comed continues to pursue this change.

NRC RAI Number E bi ed Date RAI Status 3.9.7 04 k3/97 Open.NRC Action Required NRC Description of issue 3.9.7 04 DOC L$

ITS LCO 3.9.7 The CTS changes identlued as L$ include less restrictive changes not discussed because CTS establish water level limits when fuel assemblies or control rads are moved with irradiated fuel seated in the reactor vessel. Comment: provide a separate identification and discussion of each less restrictive change.

CamEd Response to lisue No change. Comed disagrees.- The whole purpose of DOC L$ and the relocation 6f" irradiated" fuel assemblies is discussed in LAi1. Comed continues to pursue this change.

NRC RAI Number NRC lasued Date RAI Status 3.9,7 05 12/5/97 Open. NRC Action Required NRC i escription of issue 3.9.705 JFD C4 ITS 3.9.7 Applicability JFD C4 ptoposes to revise the STS format for constructing applicable conditions. Comment: This is a generic change that requires a stafT approved TSTF change. Revise the submittal to adopt the STS.

Comed Response to issue WOO 81 will be withdrawn from the ITS submittal. ITS and NUREG will be revised to adopt the ISTS presentation in the Applicability section ofITS LCOs 3.9.4 and 3.9.7. As a result, LCO_ JFD 3.9-C4 will be deleted. This charige will be provided in our comprehensive ITS Section 3.9 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3,9 RAl. (See RAls 3.7,10-03,3.7.1102,3.7.13 06, and 3.9.4-06.)

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