Text

Application for Technical Specifications Change to Add LCO 3.0.9 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process
	ML19032A149
Person / Time
Site:	Byron, Braidwood
Issue date:	01/31/2019
From:	Gullott D; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-19-008
	Download: ML19032A149 (29)
	v • d • e

Exelon Generation 4300 Winfield Road Warrenville. IL 60555 www.exeloncorp.com RS-19-008 10 CFR 50.90 January 31, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Application for Technical Specifications Change to Add LCO 3.0.9 on the lnoperability of Snubbers Using the Consolidated Line Item Improvement Process

References:

1. TSTF-372-A, Revision 4, Addition of LCO 3.0.8, lnoperability of Snubbers,"

11 dated April 27, 2004

2. Notice of Availability of Model Application Concerning Technical Specification Improvement to Modify Requirements Regarding the Addition of Limiting Condition for Operation 3.0.8 on the lnoperability of Snubbers Using the Consolidated Line Item Improvement Process, dated May 4, 2005 (70 FR 23252)

In accordance with 10 CFR 50.90, Exelon Generation Company, LLC (EGC) is submitting a request for an amendment to the Technical Specifications (TS) for Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2.

The proposed amendment would modify TS requirements for inoperable snubbers by adding Limiting Condition for Operation (LCO) 3.0.9. The change is consistent with the Nuclear Regulatory Commission (NRC) approved Revision 4 to Technical Specification Task Force (TSTF) Standard Technical Specifications Change Traveler, TSTF-372, "Addition of LCO 3.0.8, lnoperability of Snubbers" (Reference 1). The availability of this TS improvement was announced in the Federal Register on May 4, 2005 (70 FR 23252) as part of the consolidated line item improvement process (CLllP) (Reference 2).

Due to the already existing LCO 3.0.8 within Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2 TS, adoption of TSTF-372 will be identified as LCO 3.0.9. This deviation in nomenclature is insignificant with regard to ensuring proper application of TSTF-372, Revision 4, intent and purposes.

U.S. Nuclear Regulatory Commission January 31, 2019 Page 2 The proposed changes have been reviewed by the Braidwood Station and Byron Station Plant Operations Review Committees in accordance with the requirements of the EGC Quality Assurance Program. provides a description of the proposed change, the requested confirmation of applicability, assessment, regulatory analysis, and environmental consideration of the proposed changes. Attachments 2 and 3 provide the existing TS pages for Braidwood Station and Byron Station, respectively, marked up to show the proposed change. Attachment 4 provides a summary of the regulatory commitments made in this submittal. Attachments 5 and 6 provide the existing TS Bases pages for Braidwood Station and Byron Station, respectively, marked up to show the proposed changes (for information only).

EGC requests approval of the proposed License Amendment by August 7, 2019, in accordance with the Consolidated Line Item Improvement Process (CLllP). This date will also support the Braidwood Unit 1 fall refueling outage (A 1R21 ). Upon issuance, the amendments shall be implemented within 30 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the State of Illinois.

If you should have any questions regarding this submittal, please contact Ms. Lisa Simpson at (630) 657-2815.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 31st day of January 2019.

Respectfully, David M. Gullatt Director - Licensing Exelon Generation Company, LLC Attachments:

1. Description and Assessment

2. Proposed Technical Specifications Changes for Braidwood Station, Units 1 and 2

3. Proposed Technical Specifications Changes for Byron Station, Units 1 and 2

4. Regulatory Commitments

5. Proposed Technical Specifications Bases Changes for Braidwood Station, Units 1 and 2

6. Proposed Technical Specifications Bases Changes for Byron Station, Units 1 and 2 cc: NRC Regional Administrator - Region Ill NRC Senior Resident Inspector- Braidwood Station NRC Senior Resident Inspector- Byron Station NRC Project Manager, NRA - Braidwood and Byron Stations Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 1 Description and Assessment

1.0 DESCRIPTION

The proposed amendment would modify Technical Specifications (TS) requirements for inoperable snubbers by adding Limiting Condition for Operation (LCO) 3.0.9.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specifications Change Traveler TSTF-372, Revision 4, Addition of LCO 3.0.8, lnoperability of Snubbers. The 11 11 availability of this TS improvement was published in the Federal Register on May 4, 2005 (70 FR 23252) as part of the consolidated line item improvement process (CLllP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Exelon Generation Company, LLC (EGC) has reviewed the Model safety evaluation (SE) dated May 4, 2005, as part of the CLllP. This review included a review of the NRC's evaluation, as well as the supporting information provided to support TSTF-372, Revision 4. EGC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC are applicable to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, and justify this amendment for the incorporation of the changes to the Braidwood Station and Byron Station TS.

2.2 Optional Changes and Variations 2.2.1 EGC proposes the following minor variation from the TS and Bases changes described in the TSTF-372, Revision 4, and the NRC's model safety evaluation dated May 4, 2005:

The Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, TS currently contain an LCO 3.0.8 that pertains to the applicability of Actions throughout the TS for these dual-unit facilities. Specifically, LCOs shall apply to each unit individually, unless otherwise indicated. Whenever the LCO refers to a system or component that is shared by both units, the LCOs will apply to both units simultaneously. This LCO is renumbered as LCO 3.0.9 to align with TSTF-372-A for the affected plants.

This variation is administrative in nature and does not affect the applicability of TSTF-372 to the Braidwood, Units 1 and 2, or Byron, Units 1 and 2 TS. Attachments 5 and 6 provide the existing TS Bases pages for Braidwood Station and Byron Station, respectively, marked up to show the proposed changes (for information only).

2.2.2 EGC is not proposing any variations or deviations from the TS changes described in TSTF-372, Revision 4, or the NRC Model SE. However, based on Revision 1 of TSTF-IG-05-03, lmplementation Guidance for TSTF-372, Revision 4, 'Addition of 11 LCO 3.0.8, lnoperability of Snubbers', issued February 2009, EGC is proposing minor 11 deviations from the N RC Model SE, associated with the maintenance of Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, TS wording and usage rules in the adoption of TSTF-372. The NRC Model SE contained the following stipulations:

Page 1 of 7

ATTACHMENT 1 Description and Assessment

1. Appropriate plant procedures and administrative controls will be used to implement the following Tier 2 restrictions [i.e., Avoidance of Risk-Significant Plant Configurations" as defined in Regulatory Guide 1.177, "An Approach for Plant Specific, Risk-Informed Decisionmaking:

Technical Specifications," August 1998].

(a) At least one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s), must be available when LCO 3.0.8a is used at PWR plants.

(b) At least one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubbers), or some alternative means of core cooling (e.g., F&B, fire water system or "aggressive secondary cooldown" using the steam generators) must be available when LCO 3.0.8b is used at PWR plants.

(c) LCO 3.0.8b cannot be used by West Coast PWR plants with no F&B capability when a snubber, whose non-functionality would disable more than one train of AFW in a seismic event of magnitude up to the plant's SSE, is inoperable.

(d) BWR plants must verify, every time the provisions of LCO 3.0.8 are used, that at least one success path, involving equipment not associated with the inoperable snubber(s), exists to provide makeup and core cooling needed to mitigate LOOP accident sequences.

(e) Every time the provisions of LCO 3.0.8 are used licensees will be required to confirm that at least one train (or subsystem) of systems supported by the inoperable snubbers would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads. LCO 3.0.8 does not apply to non-seismic snubbers. In addition, a record of the design function of the inoperable snubber (i.e., seismic vs. non-seismic), implementation of any applicable Tier 2 restrictions, and the associated plant configuration shall be available on a recoverable basis for staff inspection.

2. Should licensees implement the provisions of LCO 3.0.8 for snubbers, which include delay times to enter the actions for the supported equipment when one or more snubbers are out of service for maintenance or testing, it must be done in accordance with an overall

[configuration risk management program (CRMP)] to ensure that potentially risk-significant configurations resulting from maintenance and Page 2 of 7

ATTACHMENT 1 Description and Assessment other operational activities are identified and avoided, as discussed in the proposed TS Bases. This objective is met by licensee programs to comply with the requirements of paragraph (a)(4) of the Maintenance Rule, 10 CFR 50.65, to assess and manage risk resulting from maintenance activities or when this process is invoked by LCO 3.0.8 or other TS. These programs can support licensee decisionmaking regarding the appropriate actions to manage risk whenever a risk-informed TS is entered. Since the 10 CFR 50.65(a)(4) guidance, the revised (May 2000) Section 11 of NUMARC 93-01, does not currently address seismic risk, licensees adopting this change must ensure that the proposed LCO 3.0.8 is considered in conjunction with other plant maintenance activities and integrated into the existing 10 CFR 50.65(a)(4) process.

Each of these stipulations is addressed below.

Stipulations 1(a) and 1(b)

Stipulations 1(a) and 1(b) are incorporated in the associated TS Bases for LCO 3.0.9.

When this proposed amendment is approved, associated plant procedures will be revised to include these requirements.

Stipulation 1(c)

Stipulation 1(c) is applicable only to West Coast PWR plants; therefore, it is not applicable to Braidwood Station, Units 1 and 2, or Byron Station, Units 1 and 2.

Stipulation 1(d)

Stipulation 1(d) is applicable only to BWR plants; therefore, it is not applicable to Braidwood Station, Units 1 and 2, or Byron Station, Units 1 and 2.

Stipulation 1(e)

Regarding Stipulation 1(e), the revised Bases state that every time the provisions of LCO 3.0.9 are used, EGC will confirm that at least one train (or subsystem) of systems supported by the inoperable snubbers will remain capable of performing their required safety or support functions for postulated design loads other than seismic loads.

Item 1(e) of the Model SE, Section 3.2, contains the statement LCO 3.0.8 does not 11 apply to non-seismic snubbers. This statement is not specifically addressed in the 11 implementation process of TSTF-372; therefore, EGC proposes to include this statement in the LCO 3.0.9 Bases (see Attachments 5 and 6 of this submittal). Further guidance associated with the intent of this statement, as discussed in Section 3.0 of the Model SE and in TSTF-IG-05-03, lmplementation Guidance for TSTF-372, Revision 4, 'Addition of 11 LCO 3.0.8, lnoperability of Snubbers', is also included in the Bases.

11 Page 3 of 7

ATTACHMENT 1 Description and Assessment Stipulation 2 Stipulation 2 of the NRC Model SE directs that decision making must ensure that the proposed LCO 3.0.9 and seismic risk is considered in conjunction with maintenance activities. The revised TS Bases for LCO 3.0.9 provide guidance and details on how to implement the new requirements. LCO 3.0.9 requires that risk be managed and assessed. The revised Bases also state that while the Industry and NRC guidance on implementation of 10 CFR 50.65(a)(4), the Maintenance Rule, does not address seismic risk, LCO 3.0.9 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified but may be a qualitative assessment of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function. Finally, EGC has a Bases Control Program (TS 5.5.14) consistent with Section 5.5 of the Standard Technical Specifications.

The proposed TS Bases changes are consistent with those described in TSTF-372, Revision 4, except that the specific restrictions identified in the NRC Model SE dated May 4, 2005, are added to the proposed new TS Bases for LCO 3.0.9. These variations do not affect the proper application of TSTF-372.

2.2.3 EGC proposes the following minor variation from TSTF-372, Revision 4:

The model application provided in TSTF-372, Revision 4, includes an attachment for revised (clean) TS pages reflecting the proposed changes. Braidwood Station and Byron Station are not including attachments for revised TS pages as they may have the potential to be affected by other unrelated license amendment requests and due to the straightforward nature of the proposed changes. Providing only mark-ups of the proposed TS changes satisfies the requirements of 10 CFR 50.90, Application 11 for amendment of license, construction permit, or early site permit, in that the mark-ups fully describe the changes desired.

This variation is an administrative deviation from TSTF-372, Revision 4, with no impact on the NRC's model safety evaluation. Because of this deviation, the contents and numbering of the attachments for this amendment request differ from the attachments specified in the model application in TSTF-372, Revision 4.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination In accordance with 10 CFR 50.90, Exelon Generation Company, LLC (EGC), is submitting a request for an amendment to the Technical Specifications (TS) for Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2.

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ATTACHMENT 1 Description and Assessment The proposed amendment would modify TS requirements for inoperable snubbers by adding Limiting Condition for Operation (LCO) 3.0.9. The change is consistent with the Nuclear Regulatory Commission (NRC) approved Revision 4 to Technical Specification Task Force (TSTF) Standard Technical Specifications Change Traveler, TSTF-372, "Addition of LCO 3.0.8, lnoperability of Snubbers" (Reference 1). The availability of this TS improvement was announced in the Federal Register on May 4, 2005 (70 FR 23252) as part of the consolidated line item improvement process (CLllP) (Reference 2).

EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment for Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, by focusing on the three standards set forth in 10 CFR 50.92(c), "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change allows a delay time before declaring supported Technical Specifications (TS) systems inoperable when the associated snubber(s) cannot perform its required safety function. Entrance into Actions or delaying entrance into Actions is not an initiator of any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The consequences of an accident while relying on the delay time allowed before declaring a TS supported system inoperable and taking its Conditions and Required Actions are no different than the consequences of an accident under the same plant conditions while relying on the existing TS supported system Conditions and Required Actions. Therefore, the consequences of an accident previously evaluated are not significantly increased by this change.

Therefore, this proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change allows a delay time before declaring supported TS systems inoperable when the associated snubber(s) cannot perform its required safety function. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in margin of safety?

Response: No.

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ATTACHMENT 1 Description and Assessment The proposed change allows a delay time before declaring supported TS systems inoperable when the associated snubber(s) cannot perform its required safety function. The proposed change restores an allowance in the pre-Improved Standard Technical Specifications (ISTS) conversion TS that was unintentionally eliminated by the conversion.

The pre-ISTS TS were considered to provide an adequate margin of safety for plant operation, as does the post-ISTS conversion TS.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed amendments do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

3.2 Verification and Commitments As discussed in the Notice of Availability published in the Federal Register (70 FR 23252) on May 4, 2005, for this TS improvement, plant-specific verifications were performed as follows:

EGC has established TS Bases for LCO 3.0.9 that provide guidance and details on how to implement the new requirements. LCO 3.0.9 requires that risk be managed and assessed. The Bases also state that while the Industry and NRC guidance on implementation of 10 CFR 50.65(a)(4), the Maintenance Rule, does not address seismic risk, LCO 3.0.9 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified but may be a qualitative assessment of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function. Finally, EGC has a Bases Control Program (TS 5.5.14) consistent with Section 5.5 of the Standard Technical Specifications.

EGC has provided a regulatory commitment to ensure that the TS Bases for LCO 3.0.9 will be established with the implementation of the amendment (i.e., Attachment 4). Additionally, this requirement is documented in the proposed TS Bases. The inclusion of these configuration restrictions in the TS Bases will ensure that they are retained and controlled in accordance with the TS Bases Control Program as defined in the Administrative Controls TS Section 5.5, 11 Programs and Manuals."

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ATTACHMENT 1 Description and Assessment 4.0 ENVIRONMENTAL EVALUATION A review has determined that the proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

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ATTACHMENT 2 Proposed Technical Specifications Changes for Braidwood Station, Units 1 and 2 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 Mark-up of Technical Specifications Pages 3.0-1 3.0-4 INSERT 1

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION CLCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 -aflEi--LCO 3.0.7.

_______[J--0 fS:..--1 ,and LCO 3.0.9. I- - - - - -

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b. MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

BRAIDWOOD - UNITS 1 &2 3.0 - 1 Amendment -98

LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.7 Exception LCOs allow specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Exception LCOs is optional. When an Exception LCO is desired to be met but is not met, the ACTIONS of the Exception LCO shall be met. When an Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

LCO 3.0.8 LCOs, including associated ACTIONs, shall apply to each unit individually, unless otherwise indicated. Whenever the LCO refers to a system or component that is shared by both units, the ACTIONs will apply to both units simultaneously.

BRAIDWOOD - UNITS 1 &2 3.0 - 4 Amendment -l-93

INSERT 1 LCO 3.0.9 When one or more required snubbers are unable to perform their associated support functions(s), any affected support LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. The snubbers not able to perform their associated support functions(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; or

b. the snubbers not able to perform their associated support functions(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

ATTACHMENT 3 Proposed Technical Specifications Changes for Byron Station, Units 1 and 2 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 Mark-up of Technical Specifications Pages 3.0-1 3.0-4 INSERT 1

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION CLCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 -a-Afi-LCO 3.0.7.

10=1' ~ ,and LCO 3.0.9. li---- - - -