ML20199K838

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Submits Paragraphs Which Discuss Differences Noted Between TSTF-135 Rev 0 & Util Submittal for Section 3.3 LCOs 3.3.1 & 3.3.2
ML20199K838
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 01/29/1998
From: Stanley H
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9802090031
Download: ML20199K838 (6)


Text

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f Q>mn.nnweahh Frkn Gimpany iWl Opus Pl.n e Downers Grove. !!, M615-5?Oi Januhry 29,199d Un'ited States Nuclear Regulatory Commission AttenUon: Document Cortrol Desk Washington, DC 20555-0001

Subject:

TSTF-135 Revision 0 comparison of Instrumentation Section 3.3 for Amendment to Appendix A, Technica! Specifications, for Facility Operating Licenses:

l Byron Nuclear Power Station, Unit 1 and 2 Facility Operating Licenses NPF-37 and NPF-66 NRC Docket Nos. 50-454 and 50-455 Braldwood Nuclear Power Station, Unit 1 and 2 Facility Operating Licenses NPF-72 and NPF-77 j

NRC Docket Nos. 50-456 and 50-457

Reference:

1.

Gene Stanley and Ken Graesser (Commonwealth Edison) letter to NRC Document Control Desk,

" Conversion to the Improved P

'ard Technical Specifications," dated Decembc.3,1996 As requested in the December 15,1997 meeting between representatives of Commonwealth Edison (Comed) and the NRC staff, Corned has identified the deviations between TSTF-135 Revision 0 and the Comed submittal (Reference 1) for Section 3.3 LCOs 3.3.1 and 3.3.2. The following paragraphs discuss the differences we have noted.

The generic changes (TSTFs) included in the Comed submittal for the LCOs and bases for Section 3.3 are TSTF 135 Revision 0, identified as Justification for Difference (JFD) C3 and TSTF-169 (WOG-80), identified as JFD C. the NRC staff 5

approved TSTF 169 during the October 1997 TSTF meeting.

Another deviation from TSTF-135 Revision 0 is a beyond scope change included in Section 3.3 and identified in Attachment 5 for tiie Split Report. The change was identified as. item #3 in the attachmeiit, addressing Auxiliary Feed Water pump inoperability of LCO 3.3.2 and justified at a plant specific change to the NUREG LCOs, P e, and a less re,stpctive change to CTS, L7 i

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9002090031 90012 PDR ADOCK 05000454

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U.S. NRC Januaru 29,1998 There are 35 other plant specific changes made to TSTF-135 Revision 0, and identified in the Jusufication for Differences to the NUREG-1431 LCOs section of the ITS submittal. Thirteen of the identified changes delete conditions and footnotes not required per the current Byron /Braidwood Technical Specifications, or are reflected in another applicable condition of the LCO. These changes are identified in Attachment A.

Also identified, are 16 plant specific changes to TSTF-135 Revision 0 that reflect current plant requirements, wording, and design. These changes are identified in Attachment B.

There have been two plant specific changes to TSTF-135 to match the intent indicated in the bases:

Pi2 TSTF-135 LCO 3.3.2, Required Action P.1 is revised to match the Bases which indicate the unit must be put in a Mode for which the Function is not required.

P4s ITS LCO 3.3.1 Required Actions D.1, J.1, and L.1, and LCO 3.3.2 Required Actions B.1, D.1, F.1, G.1, H.1, K.1,0.1, and 0.1 are revised to match the intent as described in the associated Bases. Each of 3

these Required Actions are revised from " Restore channel (s)..." to

/

" Restore all but one channel..."

Three other plant specific changes to TSTF-135 revise the NUREG specified wording to reflect proper function:

P7 TSTF-135 Table 3.3.1-1, Function 11, Footnote (g), and associated Bases have been revised to reflect one function rather than two separate functions Psi TSTF-135 Table 3.3.1-1, Function 15, Footnote (f), and associated Bases have been revised to reflect the Mode of Applicability for the Turbine Trip Function.

Ps TSTF-135 Table 3.3.2-1, Function G.a and Function 6.b and t

associated Bases have been revised to combine the two Functions.

This identifies all deviations from the generic traveler, TSTF-135 Revision 0. We hope this will assist you in your review of the Byron and Braidwood ITS submittal for 'he Instrum 2ntation Section 3.3.

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U.S. NRC January 29,1998 Please address any comments or questions regerding this matter to our Nuclear Licensing Department.

3 Sincerely,

/

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'H, Gen Stanley PWR Vice Pres ent U :

Identified Plant Specific C!.anges that delete conditions and footnotes not required per the current Bynn/Braidwood Technical Specifications, or are reflected in unother applicable condition of the LCO. :

Identified Plant Specific Changes to TSTF-135 that reflects current plant requirements, wording, and design.

cc: Regional Administrator-Region lil, NRC Byron Project Manager - NRR/DRPW/PD-Ill-2 Braidwood Project Manager-NRR/DRPW/PD-Ill-2 Senior Resident inspector-Braidwood Etation Senior Resident inspector - Byron Station Office of Nuclear Sa'ety-IDNS Craig Harbuck - NRR/ADPR/TSB 1

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ATTACHMENT A Identified Plant Specific Changes that delete conditions and footnotes not required per the current Byron /Braidwood Technical Specifications, or are i

reflected in at.other applicable condition of the LCO.

P2 NUREG as modified by TSTF-135 Condition M of LCO 3.3.1 and associated Bases have been deleted.

P3 NUREG as modified by TSTF-135 Condition O and Condition P of LCO 3.3.1 and associated Bases have been deleted.

Ps NUREG as modified by TSTF-135 Table 3;3.1-1, Footnote (f), arid associated Bases have been deleted.

l Pio NUREG as modified by TSTF-135 Table 3.3.1-1, Function 15, and associated Bases have been deleted.

Pi4 NUREG as modified by TSTF-135 Table 3.3.2-1, Function 1.e.2, Function 1.f, Funvion 1.g, Function 4.e, Function 4.f, Function 4.g, Function 4.h, Function 7.c, Footnote (d), Footnote (e), Footnote (f), Footnote (i), and associated Bases have been deleted.

Pi7 NUREG as modified by TSTF-135 Condition Q of LCO 3.3.2 and associated Bases have been deleted.

Pts NUREG as modified by TSTF-135 Table 3.3.2-1, Function 6.g, Condition S of LCO 3.3.2, and associated Bases have been deleted.

Pio ITS SR 3.3.2.11 Note and associated Bases have been deleted.

P2o NUREG as modified by TSTF-135 Condition F of LCO 3.3.2 and associated Bases as it applies to NUREG Table 3.3.2-1, Function 1 e, has been deleted.

P21 NUREG as modified by TSTF-135 Table 3.3.2-1, Function 2.c, and associated Bases related to the two loop option have been deleted.

P4 NUREG as modified by TSTF-135 Condition R of LCO 3.3.2 as it applies to 2

NUREG as modified by TSTF-135 Table 3.3.2-1, Function 5.b, has been deleted.

P45 NUREG as modified by TSTF-135 SR 3.3.1.12 and associated Bases have been deleted.

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ATTACHMENT B I

Identified Plant Specific Changes to TSTF-135 that reflects current plant l

  • requirements, wording, and design.

P4 The Note associated with SR 3.3.1.6 and associated Bases have been revised to reflect the plant specific requirement when the SR is required to be performed.

Pe iTS Table 3.3.1-1 and associated Bases are revised to clarify unit design.

Pe ITS Table 3.3.1-1, Function 14; Tab!c 3.3.2-1, Function 5.b, and Table 3.3.2-1, Function 6.b, have been revised to add unit specific designations for the Steam Generator Water Level functions.

P33 Condition D of ITS LCO 3.3.2 and associated Bases have been revised to place the channel in trip rather than place the channel in bypass.

P22 Condition L of ITS LCO 3.3.2, Footnote (d), ano associated Bases revised and Footnote (f) was added to reflect current design of the trip functions.

P23 ITS Toble 3.3.2-1, Function 5.b, has been revised to add surveillance requirements for the Turbine Trip and Feedwater Isolation on Steam Generator Water Level-High High.

l Ps ITS LCO 3.3.2 Condition F and associated Bases has been revised to 2

incorporate CTS LCO 3.3.2, Table 3.3-3, Function 6.f.

P27 Condition B of ITS LCO 3.3.2 and associated Bases were revised to replace the reference to " trains" with " channels" and to replace the references to

" channels" with " switches."

Ps ITS Table 3.3.2-1 Function 6.d revised to reflect Byron /Braidwood design.

2 P33 ITS SR 3.3.2.11 is added to reflect that the Byron and Braidwood auxiliary feedwater pump start on bus 141(241) undervoltage is not on a staggered test basis.

P47 TSTF-135 Table 3.3.1-1, Function 15.a and associated Bases are revised to reflect unit design of three channels per train.

P44 TSTF-135, LCO 3.3.1 Condition L wording is revised to replace the word

" loop" with the word " Function." Condition L was revised to apply to the Turbine Trip Functions.

P49 TSTF-135 Table 3.3.1-1, Function 4, is revised to include Applicability for the IRMs above the P-6 interlock setpoint.

Identified Plant Specific Changes to TSTF-135 that reflects current plant requirements, wording, and design.

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. Pso.TSTF-135 Table 3.3.21, Function 7, and the associated Bases are revised to reflect plant design. (Note correction of Table reference from ITS JFD)

Psi Condition M of LCO 3.3.1 has been revised from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to reduce power to < P 8.. This is consistent with CTS Table 3.31 Action 6.

P53 TSTF.135 Condition F and Condition G of LCO 3.3.1 has been revised.

The Completion Time "Immediately upon discovery..." has been revised to-

"Immediately from discovery..." consistent with other Completion Times in l

- the LCO.

i i

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