ML20236H616
| ML20236H616 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 07/02/1998 |
| From: | Tulon T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20236H619 | List: |
| References | |
| NUDOCS 9807070287 | |
| Download: ML20236H616 (35) | |
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Commonwealth 1:div>n Company liraidwood Generating Station Route *l, llox Ri liracn ille. II. G h07>M19 TclHis.4SR280l l July 2,1998 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington D. C. 20555 - 0001
Subject:
Revision F to the improved Technical Specifications (ITS) Submittal - ITS' Sections 1.0/2.0/3.0 Section Closecut Byron Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Numbers: 50-454 and 50-455 Braidwood Nuclear Power Station, Units 1 and 2 Facility Operating Licenses NPF-72 and NPF-77 NRC Docket Numbers: 50-456 and 50-457
Reference:
G. Stanley and K. Graesser (Commonwealth Edison) letter to NRC Document Control Desk, " Conversion to the improved Standard Technical Specifications," dated December 13,1996 The purpose of this letter is to provide Revision F to the Referenced ITS submittal. ITS Revision F contains Commonwealth Edison's (Comed's) final Package Closeout for ITS Sections 1.0,2.0, and 3.0. However, two open issues remain. Comed is awaiting the Stafi's resolution of TSTF-205 and TSTF-270 in order to close RAI 1.0-05 and RAI 1.0-06, respectively.
Enclosure I contains ITS Revision F. Attachment I contains Comed's final RAI Responses to Sections 1.0,2.0, and 3.0. Any revised response is noted along with the \),,i original response. As requested by the Staff, Attachment 2 contains an affected page list [
identifying submittal pages that have changed as a result ofincorporating RAI responses.
. Attachment 3 contains an affected page list summarizing all submittal pages that have _cl changed in ITS Revision F. {g
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- These Revisions are being provided in the same ten-section format as the initial ITS submittal:
l 1. ByronITS
, . 2. Braidwood (Brwd)ITS
[ 3. Byron CTS Markups
- 7. LCO Justification for Differences (JFDs)
- 8. Bases Markups.
. 9. Bases JFDs .
- 10. No Significant Hazards Consideration (NSHC)
Please address any comments or questions regarding this matter to our Nuclear Licensing Department.
Sincerely, k
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Timothy J. Tulon Site Vice President Braidwood Nuclear Power Station TffttMie03syt_ dos
Enclosure:
ITS Revision F Attachments: Attachment 1 - ITS Sections I.0/2.0/3.0 RAI Revised Responses Attachment 2 -ITS Sections 1.0/2.0/3.0 RAI Affected Page List Attachment 3 - ITS Sections 1.0/2.0/3.0 Section Closeout Affected Page List cc: NRC Regional Administrator - Region III Senior Resident Inspector - Braidwood Senior Resident Inspector - Byron
,, Office of Nuclear Facility Safety - IDNS 2 )
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l bec: Byron Project Manager- NRR Braidwood Project Manager - NRR l W. Beckner - NRR j R. Assa - NRR '
C. Harbuck - NRR i
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ATTACHMENT 1 !
ITS Sections 1.0/2.0/3.0 RAI Revised Responses j j
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Response to NRC RAI For ITS Section 1.0 01,iui-98 NRC RAI Number NRC issued Date RAI Status 1.0-01 8/5/97 Closed NRC Description of Issue 1.0-01 DOC-A19 CTS 1.0 - Defini%n for Shutdown Margin The definition in the CTS has been revised to conform to the definition in the STS. However, there are two markup errors in the CTS. The CTS markup does not contain "With any RCCA not capable of being fully inserted, the reactivity worth of the l RCCA must be accounted for in the determination of SDM; and" which is contained in the ITS. Also, the definition markup
! does not reference DOC A19, which justifies this change. The only reference to DOC A19 appears on CTS pages 3/4 l-l and 3/413. These pages follow the CTS 1.0 markup pages. Comment: Revise the submittal to correct these markup errors.
Comed Response to Issue Revised the ITS submittal to correct the markup errors: The CTS markups were revised to add the missing text "With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and." In addition, CTS DOC 1.0-A19 was added to the CTS markups for the definition of Shutdown Margin.
NRC RAI Number NRC Issued Date RAI Status _
l.0-02 8/5/97 Closed NRC Description ofIssue l 1.0-02 JFD-P2 ITS 1.2 Logical Connectors, Examples 1.2-1 and 1.2 2
! ITS 1.3 Completion Times, Examples 1.3-1 through 1.3-7 ITS 1.4 Frequency, Examples 1.4-1 through 1.4-3 A Titles have been added to these examples. The examples in the STS do not contain titles. These changes have been
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categorized as plant specific changes. Comment: These changes have been categorized incorrectly. These changes are generic. These are not justifiable plant specific or editorial differences.
Comed Response to issue Revised the ITS submittal to omit the titles: ITS and NUREG were revised to delete the titles from the examples in Sections -
l 1.2,1.3, and 1.4.
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R:sponse to NRC RAI For ITS Section 1.0 01-Jui-98 NRC RAI Number NRC Issued Date RAI Status l 1.0-03 8/5/97 Closed NRC Description ofissue l
1.0-030 DOC M2 and DOC A12 l TlJFD C9 LTSTF-88 0 :~ CTS Table 1.2 Note "
" SITS Table 1.1-1 Notes (b) and (c)
_ '. :STS Table 1.1-1 Notes (b) and (c) l l The CTS note is proposed to be changed by specifying that the " required" bolts be tensioned instead of "all" the bolts as l
implied by the CTS and specified in the STS. This change and difference is based on TSTF 88 which has not been approved l
by the NRC. Comment: Revise the submittal to adopt the STS wording of Notes (b) and (c) which is consistent with CTS l requirements.
l Comed Response to issue I 5/20/98 Revised Response: TSTF-88 was withdrawn from the ITS submittal and the NUREG wording adopted.
Original Response: No change. The NRC, Owner's Group Chairpersons, and utility management are scheduling a meeting to discuss generic issues (i.e., TSTFs) that involve changes to the improved Technical Specifications (ITS). The main focus of this meeting is to discuss a schedule for reviewing the TSTFs, who is reviewing the TSTFs, and what direction is to be provided to utilities which have submitted ITS and have taken credit for the TSTFs that have not yet been approved.
Therefore, the status of this RAI is pending resolution of these issues.
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NRC RAI Number - NRC Issued Date RAI Status O LO-04 8/5/97 Closed
' h. NRC Description of issue 1.0-04 SA13 l 'JFDs C3 and PS: ' :Section 5.0 JFD C9
~ STS Markup insert 1.1-5ArlTS 5.6.6 PTLR l alTS Definition of PTLR l !TSTF-4, Revision I
. TSTF-4 proposed placing the PORV lift settings in the PTLR, modifying the PTLR definition to indicate this, and removing L the reference to specifications 3.4.3 and 3.4.12 from the PTLR definition. TSTF-4 rejected by NRC on 10/28/96. In addition, JFD P5 states that the LTOP enable temperature, which was added to the PTLR definition by TSTF-4, is not included in the ITS definition of PTLR. Comment: Revise the submittal to adopt the STS definition of PTLR; delete JFDs C3 and PS. Note, DOC A13's statement that the proposed PTLR definition is consistent with the STS is incorrect because the definition is based on TSTF-4 Finally, Section 5.0 JFD C9 should be deleted and ITS 5.6.6 revised to match the STS.
Comed Response to issue 5/20/98 Revised Response: TSTF-4 was withdrawn from the ITS submittal and the NRC approved / issued CTS License Amendments #89 (Braidwood) and #98 (Byron) were incorporated.
Original Response: By letter dated May 21,1997, a revision to the Byron and Braidwood CTS was requested to relocate the Pressure and Temperature Limits in accordance with Generic Letter 96-03. At the time of the ITS Revision A submittal, the proposed change to CTS had not yet been submitted. Therefore, the proposed CTS License Amendment Request was incorporated into ITS.
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R:sponse to NRC RAI For ITS S:ction 1.0 on ,iui-98
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NRC RAI Number NRC Inued Date RAI Status 1.0-05 8/5/97 Open - NRC Action Required NRC Description ofissue 1.0-05 Channel Calibration definition CDOC A3:JFD C8 (TSTF-64):
X DOC A4DJFD C2 (TSTF-19);
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~_ Channel Operational Test (COT) definition S E DOC A3:JFD C8 (TSTF-64)
E: DOC L3:JFD C7 (TSTF-39, Rev.1)
' JTrip Actuating Device Operational Test (TADOT) definition EEDOC A3CJFD C8 (TSTF-64)
- DOC L32JFD C7 (TSTF 39, Rev.1)
The listed defmitions in the CTS are proposed to be revised as described by the DOCS and JFDs listed. The following raarkup of these CTS definitions shows the proposed changes; thejustification for each change is noted in bold typeface in brackets following the change. Language common to the corresponding STS definition is underlined.
A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel such that it responds within the required range and accuracy to known values of[Al] inputs. [Al and Pl] The CHANNEL CALIBRATION shall encompass the entire channel including the required sensors and alarm, interlock, display and'or trip functions and [A3 and C8] The CHANNEL CALIBRATION shall encompass those components, such as sensors, alarms, displays, and trip, functions, required to perform the specified safety function (s). [A3 and C8] Calibration ofinstrument channels with Resistance Temperature Detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior p and normal calibration of the remaining adjustable devices in the channel. [ A4] Whenever a sensing element is replaced, the
\, next required CH ANNEL CALIBRATION sahll include an inplace cross calibration that compares the opther sensing elements with the recently installed sensing element. [C2] The CHANNEL CALIBRATION [A4] may be performed by means of[Al] any series of sequential, overlapping calibrations [ Al], or total channel steps such that the entire channel is calibrated.
An ANALOG CHANNEL OPERATIONAL TEST COT [ A.1) shall be the injection of a simulated or actual [A2] signal into the channel as close to the sensor as practicable to verify the [A3 and C8] OPERABILITY of required alarm, interlock, display, and/or trip functions [A3 and C8] , including all components in the channel, such as alarms, interlocks, displays, and q
trip functions, required to perform the specified safety function (s). [ A3 and C8] The COT may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is tested. [L3 and C7] The ANALOG CHANNEL OPERATIONAL TEST [ Al] COT shall include adjustments, as necessary, of the required [ A3] alarm, interlock and/or [Al] Trip Setpoints such that the Setpoints are within the required range and accuracy.
A TRIP ACTUATING DEVICE OPERATIONAL TEST TADOT [Al] shall consist of operating the trip actuating device l and verifying the OPERABILITY of required alarm, interlock, display, and/or trip functions, including all components in the channel, such as alarms, interlocks, displays, and trip functions, required to perform the specified safety function (s). [ A3 and C8] The TADOT may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire trip actuating device is tested. [L3 and C7] The TRIP ACTUATING DEVICE OPERATIONAL TEST TADOT [Al]
shall include adjustment, as necessary, of the trip actuating device such that it actuates at the required setpoint within the required accuracy.
. a. DOC L3 and JFD C7 are based on TSTF 39, Revision I, which adds to the CTS and STS definitions of COT and TADOT the sentence, "The COT (TADOT) may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel (trip actuating device) is tested." TSTF-39, Rev. I, has not yet been approved by the NRC. Comment: Revise the submittal to withdraw this proposed allowance from the dermitions for COT and TADOT if A TSTF-39, Rey,1, is rejected by the NRC.
- b. DOC A3 and JFD C8 are based on TSTF-64 which attempts to clarify the CTS and STS definitions of Channel l Calibration, COT, and TADOT. TSTF-64 replaces the CTS,and STS wording describing the co_mponents that must be tested 3
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Response to NRC RAI For ITS Section 1.0 01-Jul-98
= = = .-- - - _- ~ = = = ======z in each channel. TSTF-64 has not yet been approved by the NRC. Comment: Revise the submittal to adopt the STS wording for this part the definitions for Channel Calibration, COT, and TADOT if TSTF-64 is rejected by the NRC.
.O c. DOC A4 and JFD C2 are based on TSTF-19 which revises the STS definition of Channel Calibration. TSTF 19 proposes to remove language describing how to perform a Channel Calibration for RTDs and thermocouple following replacement of a sensing element. The NRC approved TSTF-19 with modifications; NRC received TSTF 19, Revision 1, on April 7,1997, but have not yet approved it. Comment: Revise the submittal to adopt the STS wording for this part the definition for Channel Calibration if TSTF-19, Rev,1, is rejected by the NRC. Note: Adopting the language added by DOC A4 would be acceptable because the CTS definition currently does not specifically address calibration of RTDs and themocouples.
Comed Response to Issue No change. in a meeting between the NRC and the NE! Technical Specifications Task Force (TSTF) on April 17,1997, the NRC described problems that had been found with the ISTS definitions of Channel Calibration, Channel Operational Test (COT), Trip Actuating Device Operational Test (TADOT), and related definitions. Based on the NRC's suggestions, the BWROG developed revised definitions of these terms (BWROG-38). The NEI TSTF has reviewed this Traveler and agreed to the proposed changes. The traveler is currently under review by the individual Owner's Groups. Therefore, the status of this RAI is pending resolution of the traveler and review by the NRC.
NRC RAI Number NRC Issued Date RAI Status 1.0-06 8/5/97 Open - NRC Action Required NRC Description ofIssue 1.0-06:ITS 1.4 Frequency examples 1.4-3 and 1.4-4 L CWOG 74 IJFD C10
- a. WOG-74 changes "were" of the STS to "was" in example 1.4-3; the use of"were" in the STS is an intentional use of the l g subjunctive mood. Comment: Adopt the STS verb form.
- b. WOG-74 adds a fourth example to illustrate the use of a surveillance note that says, "Only required to be performed in Mode 1." This is in contrast to the note that says, "Only required to be met in Mode 1," which is addressed in example 1.4-
- 3. Comment:. List all occurrences of this note in the ITS, and explain why the Bases explanation in each case is inadequate for understanding how the note modifies the Frequency, in addition, the proposed example fails to state the time limit for performing (and meeting) the surveillance following entry into Mode 1 (this would be the Completion Time of the applicable Required Action). NRC acceptance of this example would require prior owners group and TSTF approval of a corresponding generic change to all five STS NUREGs Recommend withdrawal of example 1.4-4.
Comed Response to issue l Item a: ITS and NUREG were revised to adopt the word "were" in Section 1.4, Frequency Examples 1.4-3 and 1.4-4. Item j b; No change. WOG-74 adds a fourth example (Example 1.4-4) to illustrate the use of a Surveillance Requirement (SR) l Note that states "Only required to be performed in MODE 1." As the example states, the assumed Applicability of the l associated LCO is MODE 1,2, or 3. As the example also states "Should the 7 day interval be exceeded while operation is l not in MODE 1, this Note allows entry into and operation in MODES 2 and 3 to perform the Surveillance " Therefore, the l time limit for performing the SR is prior to (not following) entry into MODE 1. In Example 1.4 3, if the SR were not perfonned within the "specified Frequency"(plus the extension allowed by SR 3.0.2), the use of"Not required to be performed.. " permits entry into the specified condition in the Note for a specified time stated in the Note to perform the SR.
In contrast, in Example 1.4-4, if the SR were not performed within the "specified Frequency"(plus the extension allowed by SR 3.0.2), the use of"Only required to be performed.. " prohibits entry into the specified condition in the Note until the SR were performed. This kind of Note appears in the following ITS SRs: 3.1.2.2, 3.3.1.3, 3.4.3.1, 3.4.1 1.1 Note 2, 3.4.1 1.2, 3.4.14.1,3.4.16.2,3.5.1.5,3.5.4.1,3.5.4.2,3.7.1.1, and 3.7.2.1. Example 1.4-4 was added to avoid Operator confusion and a potential SR 3.0.4 or SR 3.0.3 violation. Comed continues to pursue this change.
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Response to NRC RAI For ITS Section 1.0 Oi-Jui-98
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NRC RAI Number NRC Issued Date RAI Status f
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1.0-07 8/5/97 Closed NRC Description ofissue 1.0-07:JFD Cl1 Z EITS 5.5.16 Containment Leakage Rate Testing Program CSTS definition of La
" STSTF-52 The definition of La is proposed to be omitted from the ITS and its valee specified in ITS 5.5.16. JFDI 1 states this is-consistent with the STS changes proposed by TSTF-52, which TSB modified on 10/24/96 for TSTF consideration No revisions to TSTF-52 have been submitted to date. However, defining la in the administrative controls program may be acceptable - it was accepted in the Vogtle Units I and 2 conversion to the !TS. Comment: The purpose of this comment is solely to track resolution of TSTF-52 as it relates to the adoption of Appendix J Option B for Byron and Braidwood. It may be repeated (with different en'phasis) in comments for ITS Section 3.6.
Comed Response to lasue The purpose of this comment in solely to track resolution of TSTF-52 as it relates to the adoption of Appendix J Option B for
_ . _ . _ . . Byron and Braidwood. No response required. (See RAls 3.6.1-04,3.6.1-09,3.6.2-08, and 3.0-11.)
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Response to NRC RAI For ITS S:ction 2.0 01-Jul-98 NRC RAI Number NRC Issued Date RAI Status 2.0-01 8/5/97 Closed NRC Description ofIssue 2.0-01E JFD PI ITS Figure 2.1.1-1,(page I of 1) Reactor Core Safety Limits CTS Figure 2.1-1, Reactor Core Safety Limit - Four Loops in Operation CTS Figure 2.1-1, x-axis is titled " Power (Fraction of Nominal)" ITS Figure 2.1.1-1,(page 1 of 1) Reactor Core Safety Limits, x-axis is titled " THERMAL POWER (PERCENT)". The STS and correct x-axis name is " PERCENT OF RATED j THERMAL POWER". The Figure should state the safety limit for a given thermal power level that is based on a percentage with respect to the " RATED" THERMAL POWER. The percentage must be based upon a distinctive value such as RTP to be determined as a percent of the accepted value. Comment: Revise the submittal as described.
Comed Response to Issue Revised the ITS submittal as described: The titles of the x-axes for the Byron and Braidwood Reactor Core Safety Limits Figure 2.1-1 and the ITS Reactor Core Safety Limits Figure 2.1.1-1 were revised to read " PERCENT OF RATED THERMAL POWER" consistent with NUREG-1431 Revision 1.
NRC RAI Number NRC issued Date RAI Status 2.0-02 8/3/97 Closed NRC Description ofIssue 2.0-02 JFD BPI Bases ITS 2.1.1 in the Applicable Safety Analyses, second paragraph, first sentence states that RTS serpoints are from the UFSAR analyses (Qf and the setpoint methodology study which are then used in ITS 3.3.1. Ref. 2 is correct and should not be deleted. In the last paragraph, the deletion of the UFSAR Ref. 2 appears incorrect. These deletions are per BPI which does not explain the specific technical reasons for these deletions. Comment: Revise the submittal as described.
Comed Response to issue Revised the ITS submittal as described: ITS and NUREG were revised to include "(Ref.2)" consistent with NUREG-1431 Revision 1.
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Respanse to NRC RAI For ITS Section 2.0 01-Jui-98
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NRC RAI Numbel- NRC issued Date RAI Status
/N- 2.0-03 8/5/97 Closed NRC Description ofissue l 2.0-03:JFD BP5 Bases ITS 2.1,1, page B 2.0-3 In the Safety Limits, first sentence, the reference to the figure should be to the actual figure used in the SL. Including the figure in the Bases is optional, and easy to update ifincluded. Comment: Revise JFD BP5 as noted.
Comed Response to issue No change. The Background Section of the Bases for NUREG LCO 3.1.7 (page B 3.1-39) states "An example is provided for infonnation only in Figure B 3.1.7-1" and Figure B 3.1.7-1 states "This figure for illustration only. Do not use for operation." Similarly, Figure B 2.1.1-1 states "For illustration only. Do not use for operation." RAI 3.1.6-03, states " Figure in STS is for illustrative purposes". In addition, the LCO Section of the Bases for NUREG LCO 3.2.3 (page B 3.2-31) states that " Figure B 3.2.3A-1 shows a typical target band and typical AFD acceptable operation limits" (also Ref. RAI 3.2.3-l 03); Figure B 3.2.3A-1 states "This figure for illustration only. Do not use for operation." including " illustration only" l figures in the Bases is consistent with NUREG-1431 Revision 1 The convention adopted in the Byron and Braidwood ITS ,
submittal was to delete " illustration only" figures in the Bases to eliminate the possibility of an Operator inadvertently using I a Bases figure in place of an actual figure. However, because Bases Figure B 2.1.1-1 contains more information than the LCO Figure, the figure was retained. Comed continues to pursue this change. (See RAls 3.1.6-03 and 3.2.3-03.)
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NRC RAI Number NRC Issued Date RAI Status 2.0-04 8/5/97 Closed NRC Description ofissue
, 2.0-04 JFD BP7 i Bases ITS 2.1.2, page B 2.0-7 In the Background discussion, second paragraph, the addition of the text is acceptable. However, the JFD BP7 justification implies there are approved exemptions to the ASME Code. Comment: Revise JFD BP7 with a more detailed explanation and technical basis for this difTerence.
Comed Response to Issue Revised the ITS submittal to expand Bases JFD 2.0-P7 as follows: "Per 10 CFR 50.55a(3), relief from ASME Code requirements can be granted by NRR if alternative methods provide an acceptable level of quality and safett, or if compliance with Code requirements would result in hardship or unusual difficulty wi'hout a compensating increase in quality and safety. These exemptions from ASME Code requirements are common for both inservice inspection of components and ,
inservice testing of pumps and valves. In addition,10 CFR 50.55a(g)(5)(ii) states that if a revised insen ice inspection l program conflicts with the Technical Specifications, the Licensee shall apply to the NRC for amendment to the Technical i Specifications to the revised program." l
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i Response to NRC RAI For ITS Section 2.0 OI-Jul-98 NRC RAI Number NRC issued Date RAI Status .
I 2.0-05 8/5/97 Closed NRC Description ofissue 2.0-037 JFD BP2 i Bases ITS 2.1.2, page B 2.0-9 ;
In the discussion of Safety Limit Violations, the differencejustified by JFD BP2 deletes the words "the RCS pressure" in lieu I of SL "2.1.2" This change is equivalent but it eli minates a clear identification that the safety limit under discussion is the one conce ning the "RCS pressure" SL rather thart using a numerical identification. Comment: Revise the submittal to adopt th: STS wording.
Comed Response to Issue l Revised the submittal to adopt Byron and Braidwood ITS wording for referencing Specifications: ITS and NUREG have been revised to replace NUREG wording "the RCS Pressure SL" in the Safety Limit Violations Section of the Bases for NUREG SL 2.1.2 with "SL 2.1.2, "RCS Pressure SL,"" This change is consistent with the convention used throughout the ITS submhtal for referencing ITS SLs/LCOs.
NRC RAI Number NRC Issued Date RAI Status 2.0-06 8/5/97 Closed NRC Description ofIssue I 2.0-060JFD BPI I Bases ITS 2.1:2, page B 2.0-9 I in the discussion of Safety Limit Violations, JFD BPI 1 provides guidance if the SL CT is exceeded. Comment: Submit
( TSTF to incorporate BPil change into.STS.
l Comed Response to issue 5/20/98 Revised Response: This change has been accepted by the NRC. No further action required.
Original Response: Comed will submit a traveler at the next Westinghouse Owner's Group (WOG) ITS meeting scheduled l
for November 19 and 20,1997 to propose the Byron and Braidwood plant specific change to the WOG. In the interim, '
Comed continues to pursue this change.
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NRC RAI Number NRC Issued Date RAI Status 3.0-01 12/5/97 Closed NR'C Description of issue 3,0-01::: DOC LA 1 CTS 3.0.5 and 4.0.6 Both Byron and Braidwood are dual unit sites; therefore, CTS 3.0.5.a and b are essential to understanding how the LCOs. in the CTS and now in the ITS, apply equally or individually to each unit. The STS was developed based upon a singfe 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" This is because the STS only permits Notes in the body of the requirements. Comment: Identify all Unit I and 2 shared systems or shared supportir.g systems to the ITS LCOs. DOC LAl mu;t be rewritten as an administrative change to retain CTS 3.0.5 and CTS 4.0.6.
Comed Response to issue 5/20/98 Revised Response: ITS LCO 3.0.8 and ITS SR 3.0.5 were added to the submittal consistent with CTS LCO 3.0.5 and CTS SR 4.0.6 for the application of the single set of Technical Specifications to dual units.
Original Response: 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-LAI 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.
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R sponse to NRC RAI For ITS Section 3.0 01-J ui-98 NRC RAI Number NRC Issued Date RAI Status 3.0-02 12/5/97 Closed NRC Description of Issue 3.0-25 CJFD BPI O E 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 a
"In this instance," replaces "where this is the case" "and the new LCO is not met" is added "new" replaces " associated" Page B 3.0-3 and LCO 3.0.3 "no single Condition or combination . . that corresponds" replaces ~.;"no combination . . that exactly corresponds"
". . warranted. 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 specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered"
= "LCO" replaces " Specification" 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 " Specification" Page B 3.0-8 and LCO 3.0.6
" systems' Conditions " replaces " systems' LCOs' Conditions . "
- O lQ Page B 3.0-13 and SR 3.0.3
= " delay period" replaces " time limit" Page B 3.0-13 ar.d SR 3.0.3
- " . MODE changes imposed by: Required Actions or a reactor trip." replaces " .. MODE changes imposed by Required Actions."
Comment: These differences are not justifiable on a plant-specific or editorial basis. Revise the Basea 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 differences, the only changes are wording preferences which l 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 l maintain our current wording, and continues to pursue this change.
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NRC RAI Number NRC Issued Date RAI Status O 3.0-03 NRC Description of issue 12/5/97 Cowd 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.1.110 wever, 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 coaform to the Bases for STS LCO 3.0.1 as modified by TSTF-08, Rev.1.
Comed Response to hsue 5/20/98 Revised Response: TSTF-8, Revision 2, was incorporated in ITS Revision C.
Original Response: TSTF-8, Revision 2, will be incorporated, and Bases JFD 3.0-C2 will be revised to state, "This change is consistent with NUREG-1431, as modified by TSTF-8, Revision 2. This change will be provided in our comprehensive ITS Section 3.0 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.0 RAI.
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NRC RAI Number NRC issued Date RAI Status 3.0-04 12/5/97 Closed NRC Description ofIssue 3.0-4: EJFDs P1 and C5
' ~JFDs BC7 and P2 11TS LCO 3.0.4 L Bases for ITS LCO 3.0.4, STS Bases markup page B 3.0-6 O (1) The last sentence of the first paragraph ofITS LCO 3.0.4 and the 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 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 proposed for LCO 3.0.6 in the ITS, niether of these paragraphs are needed. They should both be omitted. Comment: Revise the Bases to omit the paragraph described.
Comed Response to issue 5/20/98 Revised Response: TSTF-103 was withdrawn from the ITS submittal and the NUREG wording adopted.
Original Response: No change. As discussed in LCO JFD 3.0-P1, 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 Staffs comment is not a justifiable change. Comed continues to pursue this change.
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Response to NRC RAI For ITS Srction 3.0 Oi-aui-98 NRC RAI Number NRC issued Date RAI Status 3.0-05 12/5/97 Closed NRC Description ofIssue 3.0-052JFD C3
'. 2)FD BCS DITS 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 Comed will withdraw TSTF-1, Revision 1. This change will be provided in our comprehensive ITS Section 3.0 closeout submittal revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.0 RAl. (See RAI 3.0-06.)
NRC RAI Number NRC issued Date RAI Status 3.0 12/5/97 Closed NRC Description of Issue 3 0-062JFD C3 (?)
ijFD BC10 ZlTS LCO 3.0.6 TBases for ITS LCO 3.0.5 The ITS replaces the STS words " testing required" with " required testing" 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 Q
\j demonstrate Operability." These differences from the STS Bases are based on not-approved-by-the-NRC WOG-77, which is referenced by JFD BC10. 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 The changes to the Bases were made in accordance with WOG-77 which was approved by the Staff as TSTF-165. TSTF-1, Revision 1, which made the corresponding changes to the LCO, was rejected. Therefore, for consistency with the approved Bases changes, Comed will pursue the LCO changes on a plant specific basis. In addition, Bases JFD 3.0-C10 will replace "WOG-77" with "TSTF-165." (See RAI 3.0-05.)
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NRC RAI Number NRC Issued Date RAI Status 3.0-07 12/5/97 Closed NRC Description of Issue 1
3.0-07 : JFD C8 .
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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.
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Response to NRC RAI For ITS Scction 3.0 01-J ul-98 i
NRC RAI Number NRC lssued Date RAI Status 3.0-08 12/5/97 Closed aO NRC Description ofissue 3.0-08: Bases for ITS LCO 3.0.6 i l
The Bases of LCO 3.0.6 in NUREG-1431, Rev.1, has been revised with an example illustrating the application of the Safety l 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 1, since it has been approved.
Comed Response to issue
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5/20/98 Revised Response: TSTF-71 was intended to be only an option that could be adopted if desired (as indicated by the bracketed presentation). This option was not adopted by Byron & Braidwood Stations. The proposed example does not l alone provide any significant clarity. The entire SFDP/LCO 3.0.6 issue is new to ITS and is the subject of specific and l
detailed training. The training incorporates a variety of plant specific examples. Including a complex but generic example in the Bases of LCO 3.0.6 does not provide any useful support to operator use and understanding at Byron & Braidwood.
Furthermore, the example itselfis somewhat confusing. The support / supported relationships are not specified or obvious l without concerted study.
Original Response: The Bases will be revised to incorporate TSTF-71, Revision 1. This change will be provided in our j
comprehensive ITS Section 3.0 closeout 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 3.0-09 12/5/97 Closed NRC Description of Issue j 3.0-09 E JFD BPI 4 Bases discussion of LCO 3.0.7, STS markup page B 3.0-9 i
in the second paragraph, the deletion of The second sentence, " Compliance with Test Exception LCOs is optional." is not adopted. Comment: This is not justifiable plant cpecific or editorial difference. Revise the submittal to adopt this sentence.
Comed Response to issue Com Ed will adopt the sentence. This change will be provided in our comprehensive ITS Section 3.0 closecut submittal l revision upon NRC's concurrence with the Comed Responses to the ITS Section 3.0 RAI. (Correction Note: The word
" deletion" in the NRC Description ofIssue should be " addition.")
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Response to NRC RAI For ITS Section . 3.0 01-Jul-98
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NRC RAI Number NRC Issued Date RAI Status 3.0-10 12/5/97 Closed
'd NRC Description of Issue 5
3.010]JFD 12 31FD BP5 (and reference to NRC-rejected TSTF-41) i C CITS 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 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
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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 as justified 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.) j
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NRC RAI Number NRC issued Date RAI Status .;
3.0-11 12/5/97 Closed NRC Description of Issue 3.0-11 CJFD BC6
- . The third paragraph of the STS Bases for STS SR 3.0.2 presents an example of a surveillance for which the allowance to jp extend the specified Frequency by 25% would not be permitted (a containment leakage rate testing surveillance). STS jQ 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
- Staffhas not yet approved TSTF-52. In addition, the proposed change to the Bases obscures the point trying to be made - the reason the 25% allowance does not apply.
l R.evise the submittal consistent with the plant-specific resolution ofissues related to adopting Option B, but make sure the Bases clearly explain why the 25% allowance does not apply to the surveillance described in the example.
l 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." (See RAls 1.0-07,3.6.1-04,3.6.1-09, and 3.6.2-08.)
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ATTACHMENT 3 ITS SECTIONS 1.0/2.0/3.0 SECTION CLOSEOUT I AFFECTED PAGE LIST SECTION/ TAB REMOVE PAGE INSERT PAGE 2.0 BRWD ITS 2.0-1 2.0-1 2.0-2 2.0-2 B 2.0-1 B 2.1.1-1 B 2.0-2 B 2.1.1-2 B 2.0-3 B 2.1.1-3 B 2.0-4 B 2.1.1-4 B 2.0-5 B 2.1.1-5 B 2.0-6 8 2.1.1-6 B 2.0-7 8 2.1.2-1 B 2.0-8 8 2.1.2-2 B 2.0-9 B 2.1.2-3 8 2.0-10 B 2.1.2-4 2.0 BYRON CTS MARKUPS 2-2 2-2 2-5 2-5 2.0 BRWD CTS MARKUPS 2-2a 2-2a 2-5 2-5 2.0 LCO MARKUPS INSERT 2.0-2A INSERT 2.0-2A 2.0 LCO JFDs 2.0-1 2.0-1 2.0 BASES MARKUPS B 2.0-2 B 2.0-2
, B 2.0-9 B 2.0-9 2.0 BASES JFDs 2.0-1 2.0-1 2.0-2 2.0-2 X 2.0-2a 3.0 BYRON ITS 3.0-1 THROUGH 3.0-5 3.0-1 THROUGH 3.0-6 B3.0-1 THROUGH B3.0-18 B3.0-1 THROUGH B3.0-18 3.0 BRWD ITS 3.0-1 THROUGH 3.0-5 3.0-1 THROUGH 3.0-6 B3.0-1 THROUGH B3.0-18 B3.0-1 THROUGH B3.0-18 O 5
,_ ATTACHMENT 3
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ITS SECTIONS 1.0/2.0/3.0 SECTION CLOSE0VT AFFECTED PAGE LIST SECTION/ TAB REMOVE PAGE INSERT PAGE 3.0 BYRON CTS MARKUPS 3/4 0-1 3/4 0-1 INSERT 3.0-1D/E INSERT 3.0-10/E 3/4 0-3 3/4 0-3 3.0 BRWD CTS MARKUPS 3/4 0-1 3/4 0-1 INSERT 3.0-1D/E INSERT 3.0-10/E 3/4 0-3 3/4 0-3 3.0 CTS DOCS 3.0-9 3.0-9 X 3.0-12a 3.0 LC0 MARKUPS 3.0-2 3.0-2 3.0-3 3.0-3 X INSERT 3.0-3A 3.0-5 3.0-5 t'~' X INSERT 3.0-5A
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3.0 LCO JFDs 3.0-1 3.0-1 3.0-2 3.0-2 3.0 BASES MARKUPS B 3.0-1 B 3.0-1 B 3.0-6 B 3.0-6 INSERT B 3.0-6A/B/C INSERT B 3.0-6A/B/C B 3.0-7 B 3.0-7 B 3.0-9 8 3.0-9 X INSERT B 3.0-9A B 3.0-10 B 3.0-10 l B 3.0-11 B 3.0-11 j B 3.0-14 B 3.0-14 B 3.0-15 B 3.0-15 !
INSERT B 3.0-15A INSERT B 3.0-15A 3.0 BASES JFDs 3.0-1 3.0-1 3.0-2 3.0-2 3.0 NSHC X 3.0-14a X 3.0-14b iD l
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Enclosure 1 O
ITS Revision F
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