ML20198C318

Proposed Tech Specs 3.7.1.3 Re Condensate Storage Tank

ML20198C318
Person / Time
Site:	Byron, Braidwood
Issue date:	12/30/1997
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20198C303	List: ML20198C296 ML20198C318
References
NUDOCS 9801070246
Download: ML20198C318 (24)

Text

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determined in the Reference 8 calculation. The proposed levels ensure that the acceptance criteria far the afft;cted design basis accidents contained in the UFSAR continue to be met, i

'the AF instrumentation modification is planned for Ilyron Unit 1 dt. ring U1R08 (fall 1997), for  ;

liyron Unit 2 during 132R07 (spring 1998), and for Ilraidwood Unit 2 during A2R08 (fall 2000). For  !'

Ilraidworxl Unit 1, the CST will be raised during A1R07 (fall 1998), and the AF instmmentation will oc modified during A1R08 (spring 2000).

- G. IMPACT ON PREVIOUS SUBMITTA13 .i 5

This License Amendment request does not impact any other licensing submittals, except for the [

- proposed cotivettion to the ffS (Reference 1). Note that markup pages are provided for both the  ;

Cl!S and proposed ITS.

11.; SCilEDULE REQUIREMENTS - [

l

, *1 nere are no specific sche 61c requirements for this Jr . tral.13yron and Unudwood Stations are - .

operating with administrative limits ou minimum CST level that are conservative with respect to l current TS. There admiaiatrative limits will remain in effect until the amendment request is l approved, at which time the applicabk administrative limit will become the TS minimum allowable v:due.

I. REFERENCES l L 1. " Conversion to the improved Technical Spcdfications," letter from K. Graesser (Comed) to L NRC Document Control Desk, dated December 13,1996.

2. " Auxiliary Feedwater Storage Requirements," CCE 97153/ CAB-97-129, B. S. Ii.amphries (Westmghouse) to R. Waninski (Comed), dated April 4,1997. ,

L 3. " Analysis of AISV Pump Suetion Transients for Byron and llraidwood Stations Using

REl.AP5M3," Comed Calculation PSA B-96 05, datedJune 30,1997.

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4. JEvaluation of CST Vortices for Byron and Ikaidwood Stations," Comed Calculation

. PSA.ll-9713, Revision 0, dated December 17,1997.

L 5. _" Condensate Storage Tank level Error Analysis for Byron and Braidwood Stations."

!- BYR-97-273/BRW-97 06251, dated August 5,1997, i

6. " Byron Unit 1 and Braidwood Unit 1 Condensate Stooge Tank Minimum Inventory  :

i Evaluation," Westinghouse NSD Systems Analysis Engineering analysis, SAE/FSE-CAE-0278, dated November 20,1997. t

7. ' RSG/OSG AITV Cooldown Requirement," Fri Report No. 32-1266253-02, dated December 4,1997.

- 8. " Evaluation of New CST Technical Specification Ixv-Is for Byron and Braidwood Stations,"

Comed Calculation PSA B-97-14, Rev. O, dated December 17,1997.

l 9901070245 971230 PDR- ADOCK 05000454 6 Anxwneni A.s.fety An.ym .

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9. " Auxiliary lict:dwater Pump Suction Pressure Setpoint llrror Calculation," Comlid Calculation

,N!!D 1, lilC-0186, llevision 1, December 22,1997.

10. liyroe ' perabbity Assessment 94-011, December 9,1994.

CST,UiVLDOC 7 Attwhment A fiafety Anym

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ATTACllMENT!) 1

. . i MARKED.UP PAGES FOR PROPOSED Cl{ANGES  ;

TO TECilNICAL SPECT ICATIONS,  !

i BYRON STATION UNITS 1 & 2 i

CST LEVEL / AF TRANSFER TRIP SETPOINT  !

t REVISED PAGES: i 3/4327 3/476 ,

B 3/4 7 2 l 1

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TABLE 3.3-4 (Continued)

$ EtSINEERED SAFETY FEAlURES ACTUATION SYSTER INSTR M NTATION TRIP SETPOINTS

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c. TRIP ALLOWABLE ,

3 FUNCTIONAL UNIT SETPOINT VALUE

^

C y G. Auxiliary Feedwater (Continued)

[ f. Division 11 for Unit 1 (Division 21 for Unit 2)

ESF Bus Undervoltage- .

Start Motar-Driven Pump 2870 volts 2730 volts

g. Auxiliary Feedwater .

Pump Suction Pressure- '

Low (Transfer to

. Essential Service

> Water) 1.22 Hy-wec. T Nu n-u 4 s y ,

- m- m, ,

1. #^

w 7. Automatic Opening of Containeent Sump Section f3.-  % 7 () g 4 ' I' 3 Isolation Valves Q u/5./ pSuL

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a. Automatic Actuation N.A. N.A.

Logic and Actuation Relays I

b. NWST Level-Low-Low 46. 5 44. 3 Coincident with Safety Injection See Item 1. above for Safety Injection Trip Setpoints and Allouable Values.

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PLANT SYSTEMS CONDENSATE STORAGE TANK LIMITING CONDITION FOR OPERATION 3.7.1.3 The condensate storage tank (CST) shall be OPERABLE with a contained water level of at least 404. N APPLICABILITY: MODES 1, 2, and 3.

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With the CST inoperable, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either:

a.

Restore the CST to OPERABLE status or be in at least HOT STAN0BY within theor 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and la HOT SHUTDOWN within the following b.

Demonstrate the OPERABILITY of the Essential Service Water System as a backup supply to the auxiliary feedwater pumps and restore the CST to OPERABLE status within 7 days or be in at least HOT 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 in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE HEQUIREMENTS

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4.7.1.3.1 The CST shall be demonstrated OPERABLE at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying the contained water level is within its limits when the tank is the supply source for the auxiliary feedwater pumps.

4.7.1.3.2 The Essential Service Water System shall Le demonstrated OPERABLE at least once per 12 hcurs by performing the surveiliance specified in Specifica-tion 4.7,4a. whenever the Essential Service Water System is the supply source for the auxiliary feedwater pumps.

-X 'lg /n %.l>dr IcN (.$, [ ] am[ 'h Nvrl t;: nIS df M M( s,,yt,e.ca 6 %dJ. Ag/<A & Go/2

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i BYRON - UNITS 1 & 2 3/4 7-6 /**^H' 4-

e, 3/4.7 PLANT SYSTEMS BASES 3 /4.'7.1.1 SAFETYVALVES(Continued) h,, =

Heat of vaporization for steam at the highest MSSV opening '

pressure including tolerance and accumulation, as appropriate, in BTU /lba. ,

N =

Number of loops in the plant (=4).

The values calculated from this algorithm were adjusted lower for use in Technicel Specification 3.7.1.1 to account for instrument and channel uncertainties (95 power). -

3/4.7.1.2 AUX 1tlARY FEEDWATER SYSTEM The OPERABit.lTY of the Auxiliary Feedwater System ensures that the

. Reactor Coolant System can be cooled down to less than 350*F from normal operating conditions in the event of a total loss-of-offsite power.

The motor-driven auxiliary feedwater pump is capable of delivering a total feedwater flow of 740 gpm at a pressure of 1450 psig to the entrance of .

the steam generators.

The diesel-driven auxiliary feedwa'ter pump is capable of delivering a total feedwater flow of 740 gpm at a pressure of 1450 psig to the entrance of the steam ger.crators. This capacity is sufficient to ensure that adequate feedwater flow is available to remove decay heat and reduce the Reactor Coolant System tem be placed into operation. perature to less than 350*F when the RHR System may 3/4.7.1.3 CONDENSATE STORAGE TANK la ce, whN I

The OPERABil Y of the cond sate storage ank with the minimum water "d b ] '

level f 40% ensuras hat sufficien water (200, gallons) is vailable to mainta the RCS at STAND 8Y cond ions for 9 rs with steam ischarge to the ateo here concurren with total 1 ss-of-offsit ower.

water vol limit includ an allowanc for water no sable The co because ined f tank discharge line location or her physica characterist .

3/4.7.1.4 SPECIFIC ACTIVITY The limitations on Secondary Coolant System specific activity ensure that the resultant offsite radiation dose will be limited to a small fraction of 10 CFR Part 100 dose guideline values in the event of a steam line break.

This dose also includes the effects of a coincident 1 gpa reactor to secondary tube leak in the steam generator of the affected steam line. These values are consistent with the assumptions used in the safety analyses.

BYRON - UNITS 1 & 2 B 3/4 7-2 AMENDMENT NO. p7'

3 Insert A The minimum water level required for OPliRAlllLITY in the condeasate storage tank (CST) provides 200,000 gallons o.'urable water to the suction of the auxiliary feedwater (AF) system. This amount ensures that sufficient water is available to: 1) maintain the reactor coolant system at ilOT STANDIlY conditions for 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> with steam discharge to the atmosphere concurrent with a total loss of.offsite power, and 2) maintain a unit in HOT STANDilY for two hours following a reactor trip, followed by a cooldown to 350*F in four hours, at which time the residual heat removal syttem can be put into senice.

Additionally, the minimum CST requirement provides a h'.:h probability that switchover to the essential senice water (SX) supply will not occur as long as the CST water supply remaine, available. This design feature helps maintain the long term reliability and availability of the steam generators by supp!ying higher quality condensate water to the steam generators except for circumstances where the safety.telated SX water supply is required due to the unavailability of th CST. The minimum CST levelincludes an allowance for water that may not be usable because of tank discharge line location, dynamic head loss considerations, fluid vortexing in the tank, AF pump startup suction pressure considerations, and instrument uncertainties for the CST leva and the AF suction switchover instruments.

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ATTACllMENT B-1 A MARKED UP PAGES FOR CilANGES TO PROPOSED IMPROVED TECilNICAL SPECIFICATIONS i i

13YRON STATION UNITS 1 & 2  :

i CST LEVEL / AF TRANSFER TRIP SETPOINT

-t REVISED PAGES: ,

3.3 36 3.7 13 11 3.7-35 -

i CST _1EVL DOC Ati.hment u Rev a r.r.

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'. P K A f J U MJ ECFAS Instrumtntation 3.3.2 Table 3.3.2 1 isage 1 of SI Engineered Saf ety Peature Actuation System Instrumentation AITLICABLE MODES OR OTht'R CitCIFl%D P t7.'It tD SUPVE!LLANCE Al!4WABLE FUNCTRW tisJDITIONS CHANNELS CONDITIONS RF@IFIXtWTS VALUE

6. Auxi!!any Peedwater

a. Autoestic Actuation 1,2,3 2 trains I tm 3.3.2.4 NA Ligte and Actuation SR 3.3.2.6 pelays $R 3.3.2.7

b. 90 Watet Level - Low Low 11 Unit i 1,2,3 4 g+r SG F BR 3.3.2.1 2 31.04 ER 3.3.2.6 SR 3.3.2.10 SR 3.3.2.12

2) Unit 2 1,2,3 4 g.or 80 F sk 3.3.2.1 2 14.04 ER 3.3.2.6

$R 3.3.2.10 CR 3.3.2.12

c. Safety 2njection Ref er to Function 1 (Saf ety injection) for all initiation functions and requisemaats.

d. tese of of f ette Power 1.2,3 2 F SR 3.3.3.3 4 2130 V (Undervoltage on SR 3.3.2.10 Bus 14113411) ER 3.3.2.11

e. Undervoltage Reactor 1.2 4 Q SR 3.3.2.0 2 4920 V Crv4 ant l'unt (s.or Em 3.3.2.10 traint SR 3.3.2.12

f. Auxiliary Feedwater 1.2.3 1 ter tosin M SR 3.'.2.1 > - ,. "Jn Puwp suction Taansfer ER 3.3.'.2 4 can poetion SR 3.3.2.10 tr eceut e - Low e v, A " (h h lle /6%

7 Swit chover to Contaltunent ' A c, . .t_ . 4 .-

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e. Automatic Actuation 1.2,3,4 2 teatris C SR 3.3.2.4 NA Logic and Actuation SR 3.3.2.5 Relays SR 3. 3.2. 7

b. Refuelina Water 1,2,3,4 a D SR 3,3.2.1 2 44.7%

Storage Tank IPWST) ER 3.3.2.6 Level - Low Lnw ER 3.3.2.10 ER 3.3.2.12 Colncident with Ref er to runction 1 (Safety 2njectioni for all initiation functions and requirements.

saf ety insect i m BYRON - UNITS 1 & 2 3.3-36 Revision A

• COAFT CST 3.7.6 3.7 PLANT SYSTEMS 3.7.6 Condensato Storage Tank (CST)

LCO 3.7.6 The CST level chall be 2 b 4 60 % ( 76 )o kr God 1 (kroogk cyclt 7 MJ 60*/.

APPLICABILITY: MODES 1. 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. CST level not within A.1 Verify by 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> limit, administrative means OPERADILITY of backup AND water supply.

Once por 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND A.2 Restore CST level to 7 days within limit.

D. Required Action and D.1 De in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not mrat . AND B,2 De in MODE 4, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 5

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify the CST level is 2 TDA 60'/e ( 76 8 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for Oqik Z. Nf003b Cy 'It 7 and 60'/c for VNk 2. Afttr gyclt 7.

DYRON - UNITS 1 k 2 3.7-13 Revision A

DCAFT- CST

'. B 3.7.6 BASES 4

APPLICABLE The limiting event for the condensate volume is the large SAFETY ANALYSIS feedwater line break coincident with a loss of offsite (continued) power.

A nonlimiting event considered in CST inventory determinations is a break in either the main feedwater or AF line near where the two join. This break has the potential for dumping condensate until terminated by operator action.

This loss of condensate inventory is partially compensated for by the retention of steam generator inventory.

The CST satisfies Criterion 3 of 10 CFR 50.36(c)(2) (ii) .

LCO ITo atisfy accident analysis assumptions, the CST m t con S Q sufficient cooling water to remove deca > at for 30 minu ga following a reactor trip from 102 iP, and then-to cool dow ho RCS to RilR entry conditi , assuming a coincident los f offsite power and t most adverse singlo hatfkACE failure. In doin his, it must r y*. n sufficient water to giYoie5Ug ensure adequate not p - tive au tion head for the AF pumps during cooldown, as well .ount for any losses before h isolating AF to a broken The specified level responds to roximately 200,000 gallons w is sufficient t taintain the RCS in MODE 3 at norme operating pressure and erature for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, foi ed by a cooldown to RHR entr onditions at 50 F/ hour f

The G :RABILITY of the CST is determined by maintainin the level at or above the minimum requiregi_1nvnl-APPLICABILITY In MODES 1, 2, and 3, the CST is required to be OPERABLE.

In MODE 4, 5. or 6, the CST is not required because the AF System is not required.

(continued)

BYRON - UNITS 1 & 2 B 3.7-35 Revision A

Insnijl The rninimum water level required for OPERABILITY in the condensate storage tank (CST) provides 200,000 gallons of useable water to the suction of the auxiliary feedwater (AF) system. This amount ensures that sufficient water is available to: 1) maintain the reactor coolant system at ilOT STANDl3Y conditions for 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> with steam discharge to the atmosphere conct" rent with a total loss of-ofTsite power, and 2) maintain a unit in llOT STANDdY lor two hours following a eactor trip, followed by a cooldown to 350"F in four hours, at which time the residual heat removal system can be put into service.

Additionally, the minimum CST requirement provides a high probability that switchover to the essential service water (SX) supply will not occur as long as the CST water supply remains available. This design feature helps maintain the long term reliability and availability of the steam generators by supplying higher quality conj.nsate water to the steam generators except for circumstances where the safety related SX supply is required due to the unavailability of the CST The minimum CST level includes an allowance for water that may not be usable because of tank discharge line location, dynaniic head loss considerations, fluid vortexing in the tank, AF pump startup suciion pressure considerations, and instrument uncertainties for the CST level and the AF suction switchover instruments.

q

ATTACllMENT B 2 MARKED-UP PAGES FOR PROPOSED CHANGES TO TECilNICAL SPECIFICATIONS,

, BRAIDWOOD STATION UNITS 1 & 2 CST LEVEL / AF TRANSFER TRIP SETPOINT

)

REVISED PAGES 3/4327 3/4 7 6 b 3/4 7-2 CST _LEVLIX)C Anuhnwnt B - Emied Pages

TABLE 3.3-4 (Continued) ce S ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS

g TRIP ALLOWABLE SE1 POINT VALUE

, FUNCTIONAL UNIT 9 6. Auxiliary Feedwatev (Continued)

A

, f. Division 11 for Unit 1

,, (Division 21 for Unit 2)

I y

ESF Bus Undervoltage-Start Motor-Driven 2870 volts 2730 volts Pump

g. Auxiliary Feedwater Pump Suction Pressure-Low (Transfer to Essential Service Water \ h- :Q..

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Automatic Opening of

/ 7. $re'q 7.

Containment Sump Suction Isolation Valves Ac.omatic Actuation N.A. N.A.

a.

Logic and Actuation Relays 46.7% 44.7%

l b. RWST Level-Low-Low Coincident with Safety Injection See Ites 1. above for Safety Injection Trip Setpoints and Allowable Values.

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9 3

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PLANT sfST.AS CONDENSATE STORAGE TtRK LIMITING CONDITION FOR OPERATION 3.7.1.3 The condensate storage tank (CST) shall be OPERABLE with a contained wates' level of at least-40E. g y N M

) APPLICABILITY: H0 DES,1, 2, and 3.

+ [f G

• g.ng ACTION:

o With the CST inoperable, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either:

a. Restore the CST to OPERA! E status or be in at least HOT STANDBY within tha next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> a d in HOT SHUT 00WN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or r

b. Demonstrate the OPERABILITY of the Essential Service N ar System as a backup supply to the aur.iliary feedwater pumps as cestore the 1 CST to OPERABLE . status.ytthin 72 days -or be in.at lea's .0T STANDBY I within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and ir. HOT SHUTDOWN . tit..in t.% .ci to .r.g ,

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVE*LLANCE REQUIREMENTS a _ -_=

4.7.1.3.1 The CST shall be demonstrated OPERABLE at least once per 12 hot.rs by verifying the contained water level is within its limits when the tank is the supply source for the auxiliary feedwater pumps.

4.7.1.3.2 The Essential Service Water System shall be demonstrated OPERABLE at

• least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by performing the surveillance specified in Specifica-

. tion 4.7.4a. whenever the Essential Service Water System is the supply source for the auxiliary feedwater pumps.

+ Agh c. d k .t. l b ,,4 l a l?o r Ga le cf c,,,d t. l'.,,/.} ,, fn p t+Aq /,ul4 h (4,,4 / af & (v /e 7. ,ppajgo ,,, gg,, ; x 45W Aghu,L/p /* Un.4I de, s

} ele 7. iM r cy/,y,J/p r it,,.p Q K

BRA!DWOOD - L' NITS 1 & 2 3/4 7-6 AmendmedT Wo.

_ - _ _ - - - - - - - _ -------_--_ ----_A

3/4.7 PLANT SYSTEMS

/

BASES 124.7.1.1 SAFETYVALVES(Continued) h o

- Heat of vaporization for steam at the highest MSSV opening pressure including tolerance and accumulation, as apprc piate, in BTU /lbm.

N = Number of loops in the plant (-4).

T The values calculated from this algorithm were adjusted lower for use in Technical Specification 3.7.1.1 to acco"nt for instrument and channel uncertainties (9% porer).

3 / 4. 7.1. 2 AUXILIARY FEEDWATER SYSTEM The OPERABILITY of the Auxiliary Feedwater System ensures that the Reactor Coolant System can be cooled down to less than 350*F from normal operating conditions in the event of a total loss-of-offsite power.

The meter-driven auxiliary feedwater pump is capable of delivering a total feedwater flow of 740 gpm at a pressure of 1450 psig to the entrance of the steam generators. The diesel-driven auxiliary feedwater pump is capable of delivering a total feedwater flow of 740 gpm at a pressure of 1450 psig to the entrence of the steam generators. This capacity is sufficient to ensure that adequate feedwater flow is available to remove decay heat and reduce the Reactor roolant System temperature to less than 350*F when the RHR System may R%9 be placed into operation. 'M /.aw n

3/4.7.1.3 CONDENSATE STORAGE BE

1. The OPERABILITV of the condensate siorage tank with the minimym-w&Ier 1evel of 40% ensures that sufficient water (200,000 gallersprava11able to

[maintairtthtRCS at HOT STANDBY conditions fo19 heCw th steam discharge t

\ the atmosphere Ernlurrent-wiqTs~R-offsite power. The contained swattr_ volume-limit includes an allowance for-waterJ1olusable because of tank discharge line location or other physical characteristics

~

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3/4.7.1.4 SPECTFIC ACTIVITY The limitations on Secondary Coolant System specific activity ensure that t..e resultant offsite radiation dose will be limited to a small fraction of 10 CFR Part 100 dor,e guideline values in the event of a steam line break.

This dose also includes the effects of a coincident I gpm reactor to secondary tube leak in the steam generator of the affected steam line. These values are consistent with the assumptions used in the safety analyses.

BRAIDWOOD - UNITS 1 & 2 B 3/4 7-2 AMENDMENTNO.J6

J Insert A The minimum water level required for OPERABILITY in the condensate storage tank (CST) prosides 200,000 gallons of useable water to the suction of the auxiliary feedwater (AF) system. This amount ensures that sufficient water is available to: 1) maintain the reactor '

coolant system at ilOT STANDBY conditions for 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> with steam discharge to the atmosphere concurrent with a total loss-of-ofTsite power, and 2) maintain a unit in HOT f STANDBY for two hours following a reactor trip, followed by a cooldown to 350 F in four hours, at which time the residual heat removal system can be put into service.

Additionally, the ininimum CST requirement provides a high probability that switchover to the essential service water (SX) supply will not occur as long as the CST water supply remains r allable. This design feature helps mentain the long term reliability and availability of the steam generators by supplying higher quality condensate water to the steam generators except for circumstances where the safety-related SX water supply is required due to the unavailability of the CST. The minimum CST level includes an allowance for water that may not be usable because of tank discharge line location, dynamic head loss considerations, fluid vortexing in the tank, AF pump startup suction pressure considerations, and instmment uncertainties for the CST level and the AF suction switchover instmments.

ATTACHMENT B-2A 1

MARKED 'UP PAGES FOR CllANGES TO PROPOSED IMPROVED TECHNICAL SPECIFICATIONS BRAIDWOOD STATION UNITS 1 & 2 CST LEVEL / AF TRANSFER TRIP SETPOINT REVISED PAGES: 4 3.3-36 3.7-13 B 3.7-34 CST _LEVL. DOC Attachment B . Revised Pages

4*

.. '. ESFAS Instrumentation 3.3.2 Table 3.3.2 1 (page 5 of 5)

Engineered Safety Feature Actuation System Instrumentation F TCABLE MODES OR REOUIRED SURVilLLANCE MLOWABLE

' aEP SPECIFIED C00lT10NS REQUIREMENTS VALUE FUNCTION COO!TIONS CMANNELS

6. Aux 111ery Feedwater

a. Automatic Actuation 1.2.3 2 trains  ! SR 3.3.2.4 NA Logic and Actuation :R 3.3.2.5 Relays SR 3.3.2.7

b. SG Water Level -Low Low 1,2,3 4 per SG SR ') . 3. 2.1 a 31.01

1) Unit 1 F SR J.3.2.6 SR 3.3.2.10 SR 3.3.2.12 1.2.3 4 per SG F SR 3.3.2.1 = 34.81

2) Unit 2 SR 3.3.2.6 SR 3.3.2.10 SR 3.3.2.12

c. Safety injection Refer to Function 1 (Safety injection) for all initiation functions and requirements.

d. Loss of Offsite Power 1,2,3 2 F SR 3.3.2.3 = 2730 V (Uncervoltage on SR 3.3.2.10 Bus 141(241)) SR 3.3.2.11

e. Uncervoltage Reactor 1.2 4 0 SR 3.3.2.8 = 4920 V Coolant Pump (per SR 3.3.2.10 train) SR 3.3.2.12

f. Aux 111ery Feedwater 1.2.3 1 per train M SR 3.3.2.1 . m Pwp Suction Transfer SR 3.3.2.2 on Suction SR 3.3.2.10 h / ), o.T , 9

,N Pressure - Low

7. Switenover to Containc.ent Smo a Automatic Actu& tion 1.2.3.4 2 trains C SR 3.3.2.4 NA Logic and Actuation SR 3.3.2.5 Relays SR 3.3.2.7

b. Refueling Water 1.2.3.4 4 0 SR 3.3.2.1 a 44.73 Storage Tant (RWST) SR 3.3.2.6 Leve. - Low Low SR 3.3.2.10 SR 3.3.2.12 Coincident with Refer to Function 1 (Safety injection) for all initiation functions and requirements. '

Safety injection BRAIDWOOD - UNITS 1 & 2 3.3-36 Revision A

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• CST 3.7.6 3.7 PLANT SYSTEMS 3.7.6 Cc'ndensate Storage Tank _ (CST)

OA LC0 3.7.6 The C5T level shall be a,t0t- (f% f, 4, u ,9/ Wcu 64 7, "Y **' *

O ch ? Mn Ge 4 A cry g, y, APPLICABILITY: MODES 1. 2. and 3 ACTIONS C0'10lTION REQUIRED ACTION COMPLETION TIME A. CST level not within A.1 Verify by 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> limit. administrative means OPERABILITY of backup l 6N) water supply.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter 6NQ A.2 Restore CST level to 7 days within limit.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify the CST level is = 40%. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> BRAIDWOOD - UNITS 1 & 2 3.7-13 Revision A

eST B ? 7.6 I

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BASES APPLICABLE The limiting event for the condensate volume is the large SAFETY ANALYSIS feedwater line break coincident with a loss of offsite (continued) power.

A nonlimiting event cansidered in CST inventory determinations is a break in either the main feedwater or Af line near where the two join. This break has the potential for dumping condensate until terniinated by operator action.

This loss of condensate inventory is part1C.ly compensated for by the retention of steam generator inventory.

The CST satisfit.s Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LC0 o satisfy accident analysis assumptions, the CST mus't contain sufficient cooling water to remove deca P'heat for and then 30 mi tes following a reactor trip from 102%

to co ;he RCS to RHR entry conditions assuming a oss of offsite power and the t adverse single coincide fficient water to failure. In ing this. it must reta t

ensure adequate qt positive suctiop eaa for the AF pumps during isolatingcooldown, AF to a broaN'kline/ -eli as accgunt for any losses before t' The specified level ccf spo to approximately v '1 '00.000 gallons wh9Wis sufficient to maintain the RCS in MODE 3 at nor erating pressureN qd temperature for g,g g 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, fo wed 3y a cooldown to RHRKry conditions at 50*F/ hour The-0 ERABILITY of the CST is determined by maint ining the tank level at or above the minimum required level. \j APPLICABILITY In MODES 1. 2. and 3. the CST is required to be GiERABLE.

In MODE 4. 5. or 6. the CST is not required because the AF System is not required.

(continued)

B 3.7-34 Revision A BRAIDWOOD - UNITS 1 & 2

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i Insert H The minimum water level required foi OPERABILITY in the condensate storage taak (CST) provides 200,000 gallons of uscable water to the suction of the auxiliary feedwater (AF) system. This amount ensures that sufficient water is available to: 1) maintain the reactor coolant system at 110T STANDBY conditions for 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> with steam discharge to the atmosphere concurrent with a totalloss-of-offsite power. and 2) maintain a unit in HOT STANDBY for two hours following a reactor trip, followed by a cooldown to 3507 in four hours, at which time the residual heat removal system can be put into senice.

Additionally, the minimum CST requirement provides a high probability that switchover to the essential senice water (SX) supply will not occur as long as the CST water supply remains available. This design feature helps maintain the lonb term reliability and availability of the steam generators by supplying higher quality condensate water to the steam generators except for circumstances where the safety-related SX supply is required due to the unavailability of the CST, The minimum CST levelincludes an allowance for water that may not be usable because of tank discharge line location, dynamic head loss considerations fluid vortexing in the tank, AF pump startup suction pressure considerations, and instrumcat uncertainties for t.he CST level and the AF suction switchover instruments.

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i ATTACHMENT C <

SIGNIFICANT HAZARDS CONSIDERATION Comed has evaluated this proposed amendment and determined that it invol>cs no significant hazards consideration. According to 10 CFR 50.92(c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the propml amendnient would not:

• Involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated;

• Create the possibility of a new or different kind of accident from any previously analyzed; or

• Involve a significant reduction in a margin of safety.

Commonwealth Edison (Comed) proposes to amend Appendix A, Technical Specifications (TS),

of Facility Operating Licenses NPF-37, NPU-66, NPF-72, and NPF-77. Note that in the text of this submittal, the current Technical Specification (CTS) cha.ges will be noted first, and the corresponding proposed improved Technical Specification (ITS) changes will be noted in ( }.

Comed proposea to revise 13yron and 13raidwood TS section 3.7.1.3 {3.7.6}," Condensate Storage Tank" and the associated 11ases to increase the minimum condensate storage tank (CS'l) water level to ensure that the design basis requirements for the auxiliary feedwater (AF) system are met. '

Comed proposes to increa<e the minimum value from 40% to 75% for 13yron Units I and 2, from 40% to PO% for 13raidv ood Unit 1, and from 40% to 66% for 13raidwood Unit 2. After a modification is installe on the AF suction pressure instrumentation, a minimum water level of 60%

will be required for Ilyron Units 1 and 2 and a level of 57% will be required for Ilraidwood Unit 2.

The 57% requirement will apply to 13raidwood Unit I after the AF instrumentation modification is complete, along with a modification to increase the CST height. Additionally, Comed proposes to revise the AF pump suction pressure-low trip setpoint and the allowable value ii. Table 3.3-4 (3.3.2-l}, ftmetional unit 6.g (6.f.} to retlect the design basis requirements of the AF system.

The determinatior, that the criteria set forth in 10 CFR 50.92 are met for this amendment request is indicated below:

1. The change does not involve a significant increase in the probaoility or consequences of an accident previously evaluated The amount of water in the CST at the beginning of an accident and the setpoint f;r AF pump suction pressure-low trip have no impact on the probability of occurrence of any accident analyzed in the UFSAR. This is due to the availability of the safety-related SX water supply as a backup system. Therefore, the probability of an accident previously evaluated is unchanged.

CST _LEVL. DOC 1 Atachment c . sigmricant Hmn!.

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i l 'Ihe loss of the Safety Category 11 CST under accident conditions has already been evaluated in the UFSAR. 'Ihe SX system is the emergency source of water supply to the AF system under accident conditions. 'lhe design basis analysis for the essential service water (SX) system and the Limiting Condition for Operation requirements for the ultimate heat sink ensure that a sufficient supply of water is availab5 to plant operators to mitigate the consequen;es of all analyzed accidents. None of the proposed changes to the CST minimum level or the setpoints documented in TS Table 3.3-4, functional unit 6.g. has any negative impact on the assumptions or results of these analyzed accidents. To the contrary, the pcoposed changes will ensure that the CST remains available as the primary supply of water to the AF system and that automatic suction transfer will occur for circumstances where the Safety Category 11 CST becomes unavailable (e.g., seismic event or tornado).

The levelin the CST and the associated instrumentatior and setpoints help ensure that sufhcient water is available to plant operators to mitigate the consequences of accidents that are analyzed in the UFSAR. The SX system is the emergency source of water credited in the UFSAR. Ilowever, the proposed Technical Specification Bases require that sufficient water be maintained in the CST to respond to postulated events where the CST remains available (e.g., non-seismic related events and events with no tornado assumed). The proposed CST levels ensure that this requirement is met. The water level requirement for the CST provides additional assurance that plant operators remain capable of responatng to ,

postulated events as described in the UFSAR. Therefore, the proposed changer do not /

increase the consequences of an accident previously evaluated.

Therefore this proposed amendment doer not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The change does not create the possibility of a new or different kind of accident from any accident previously evaluated The proposed changes are being implemented to account for instrument accuracy and AF ,

system suction requirements that affect the volume of useable water in the CST. The amendment request incorporates the full daign requirements of the AF System and components to ensure that sufficient water is maintained in the CST. The changes reduce the probabibty of an undesirable introduction oflower quality essential service (SX) system water into the steam generators unless required due to the unavailability of the CST during emergency conditions (e.g., seismic event or tornado). Although the SX sysicm is the safety-related water supply to AF, the water contains high levels ofimpurities and sediment that could eventually degrade the steam generators. The CST contains demineralized water.

Therefore, the long term reliability and availability of the steam generators is enhanced by 3 precluding introduction of SX water into the steam generators unless required under emergency conditions. The proposed CST levels account for the incremental increase in CST water volume required due to the larger meml mass and primary volume of the replacement steam generators for Byron Unit 1 and Eraidwood Unit 1. Finally, the trip setpoint and allowable values in Table 3.3-4 of the TS are being updated to reflect the current design basis of the AF system. The required CST level changes when plant modifications are completed. Each configuration has been evaluated and the associated CST level maintains a sufficient water volume to perform its design function.

CST _LEVL. DOC 2 Attachment c . sypure nt Huara.

1

'Ihe modi 6 cation to the suction pressure circuitry involves the addition of an electronic

" lead-lag" circuit card for the motor-driven AF pump, which experiences the most severe startup suction pressure transients. This circuit card will be set up for " lag" only operation and will filter the suction pressure signal during transients associated with pump startup or other sudden changes in flow or pressure. This will prevent an inadvertent trip during transient conditions when the CST is available in situations where the CST is unavailable, the suction pressure will decrease with no recovery until switchover. Under this condition, the output of the lead-lag card will continue to decrease as well until the switchover setpoint is reached. The time const .t of the lead-lag card was selected such that the resulting time delays in actuating SX switchover and pump trip are consistent with pump protection requirements.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated. This conclusion is also valid when considering the planned modi 6 cations to the AH suction pressure transient circuitry.

3. The change does not involve a significant reduction in a margin of safety The proposed change is made in the conservative direction with respect to the current TS requirements for minimum CST level and AF pump CST to SX switchover setpoints.

Increasing the volume of water contained in the CST level provides redundancy to the safety-related source of water to the AF supply,which is the SX system. In combination, the CST :md the SX system ensure that suf6cient water is available to feed the steam generators under ali anticipated normal and emergency conditions to cool a unit from full power conditions down to 350 F, when the residual heat removal syst-m can be placed into service. The proposed changes ensure the CST will have suf6cient water to meet all nonnal operating conditions and miti ate 3 the consequences of all analyzed accidents except those that result in CST unavailability. In addition, automatic switchover of the AF watcr supply from the CSTs to SX will occur as assumed in the current safety analyses for events where the CST becomes unavailable. The SX system remains capable of supplying the emergency source of water to the AF supply.

Therefore, the proposed chaages do not involve a significant redection in the margin of safety.

Ilased upon the above evaluation, Comed has concluded that the proposed changes involve no significant hazards consideration.

CST _LEVL. DOC 3 Attachrnent C - signiricant Huards

KITACIIMENT D ENVIRONMENTAL ASSESSMENT ,

Comed has evaluated this proposed operating license amendment request against the criteria for identi6 cation of hcensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. ComEo has detennined that this prop, sed license amendment request meets the criteria for a categorical exclusion set forth in 10 CIM 51.22(c)(9) and as such, has determined that no irreversible consequences exist in accordance with 10 CFR 50.92(b).

This determination is based on the fact that this change is be'.ng proposed as an amendment to a license issued pursuant to 10 CFR 50 that changes a requirement with respect to installation or use of a facility component located within the restricted area, u dcEned in 10 CFR 20, or that changes an inspection or a surveill:.nce requirement, and the amendment meets the following speci6c criteria:

(i) the amendment involves no signi6 cant hazards consideration.

As demonstrated in Attachment C, this proposed amendment does not involve any significant hazards consideration.

(ii) there is no signi6 cant change in the types or 3 3ni6 cant increase in the amounts of any ef0uent that may be released offsite.

Since ah safety analysis accident assumptions are met for this proposed license amendment, there will be no change in the types or increase in the amounts of any ef0uents released offsite.

(iii) there is no signi6 cant increase in individual or cumulative occupational radiation exposure.

The proposed changes will not result in significant changes in the operation or configuration of the facility. There will be no change in the level of controls or methodology used for processing of radioactive ef0uents or handling of solid radioactive waste, nor will the proposal result in any change in the normal radiatien levels within the plant. Therefore, there will be no increase in individual or cumulative occupational radiation exposure resulting from this change.

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