ML20078S830

Safety Evaluation Supporting Amends 131,125,152 & 148 to Licenses DPR-19,DPR-25,DPR-29 & DPR-30,respectively

ML20078S830
Person / Time
Site:	Dresden, Quad Cities
Issue date:	02/16/1995
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20078S827	List: ML20078S821 ML20078S830
References
NUDOCS 9502270260
Download: ML20078S830 (12)

Text

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[.Y UNITED STATES S

NUCLEAR REGULATORY COMMISSION D

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WASHINGTON. D.C. 30066 4 001 j

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO 131 TO FACILITY OPERATING LICENSE NO. DPR-19.

j AMENDMENT NO.125 TO FACILITY OPERATING LICENSE NO. DPR-25.

AMENDMENT NO 152 TO FACILITY OPERATING LICENSE NO. DPR-29.

l AND AMENDMENT NO.148 TO FACIL!TY OPERATING LICENSE NO. DPR-30

)

COMMONWEALTH EDISON COMPANY AND IOWA-ILLIN0IS GAS AND ELECTRIC COMPANY DRESDEN NUCLEAR POWER STATION. UNITS 2 AND 3 OVAD CITIES NUCLEAR POWER STATION. UNITS 1 AND 2 DOCKET NOS. 50-237. 50-249. 50-254 AND 50-265

1.0 INTRODUCTION

By letter dated July 29, 1992, as supplemented January 14, 1993, and February 16, 1993, Commonwealth Edison Company (Comed, the licensee) submitted an amendment request to upgrade Sections 1.0, 3.0/4.0, and 3/4.3 of the i

Dresden Nuclear Power Station, Units 2 and 3, and the Quad Cities Nuclear l

Power Station, Units 1 and 2, Technical Specifications (TS).

The changes have been requested as part of their Technical Specification Upgrade Program (TSUP). The staff evaluation of Section 3/4.3 will be forwarded under a separate cover.

As a result of findings by a Diagnostic Evaluation Team inspection performed by the NRC staff at the Dresden Nuclear Power Station in 1987, Comed made a i

decision that both the Dresden Nuclear Power Station and sister site Quad Cities Nuclear Power Station, need attention focused on the existing custom TS being used at both sites.

Comed made the decision to initiate a TSUP for both Dresden and Quad Cities.

Comed evaluated the TSs for both stations against the NRC accepted Standard Technical Specifications (STS) contained in, NUREG-0123 " Standard Technical Specification General Electric Plants, BWR/4".

Comed's evaluation identified numerous potential improvements such as clarifying requirements, changing the TS to make them more understandable to eliminate interpretation, and deleting requirements that are no longer considered current with industry practice.

As a result of the evaluation, Comed has elected to upgrade both the Dresden and Quad Cities TS to the STS contained in NUREG-0123.

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- The STS contained in NUREG-0123 were developed by the NRC and industry because of the shortcomings associated with the custom TS that were issued to plants licensed in the early 1970's (i.e., Dresden (1971) and Quad Cities (1972)).

The STS developed by the NRC and industry provided an adequate level of protection for plant operation by assuring required systems are operable and have been proven to be able to perform their intended functions. The limiting conditions for operation (LCO), the allowed out-of-service times, and the required surveillance frequencies were developed based on industry operating experience, equipment performance, and probabilistic risk assessment analysis during the 1970's.

The STS were used as the licensing basis for plants licensed starting in the late 1970's.

For the most part, Comed's adoption of the STS resulted in more restrictive LCOs and surveillance requirements (SR).

In some cases, however, the STSs provide relief from the Dresden and Quad Cities current TS requirements.

In all these cases, the adoption of the STS requirements for LCOs or SRs does not change the current licensing basis of either plant as it is described in the Updated Final Safety Analysis Report (UFSAR).

In addition, the success criteria for the availability and operability of all required systems contained in the current TS are maintained by the adoption of the STS requirements.

In addition to Comed adopting the STS guideline and requirements in the TSUP, Comed has also evaluated GLs concerning line item improvements for TS.

These GLs were factored into TSUP to make the proposed TS in the TSUP reflect industry lessons learned in the 1.980's and early 1990's and make the proposed TS adhere more closely to the NRC requirements.

Some examples of this were the adoption of the requirements of GL 87-09 that clarified LC0's and SRs contained in STS and GL 93-05 and 94-01, that eliminated the requirement to perform unnecessary SRs contained in the STS which were rendering safety i

systems less reliable.

The TSUP for Dresden and Quad Cities is not a complete adaptation of the STS.

The TSUP focuses on (1) the integration of additional information such as equipment operability requirements during shutdown conditions, (2) clarification of requirements such as LCOs and action statements utilizing STS terminology, (3) deletion of superseded requirements and modifications to the TS based on the licensee's responses to Generic Letters (GL), and (4) relocation of specific items to more appropriate TS locations.

The review guidance to be used by the NRC staff in the review of the TSUP is described in Section 2 of this Safety Evaluation (SE).

In the staff's review of the proposed amendments each change is evaluated and all deviatior.s between the proposed TS and the STS are justified in the attachments to this SE.

In no case did the licensee propose a relaxation of the licensing basis as stated in the UFSARs for Dresden or Quad Cities.

In response to the staff's recommendations, the licensee standardized the Quad Cities and Dresden TS. The TS are identical except for equipment and plant

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design differences. Technical differences between the units are identified as appropriate in the amendment package.

2.0 EVALUATION Review Guidelines - The licensees' purpose for the TSUP was to reformat the existing Dresden and Quad Cities TS into the easier to use STS guidelines.

Plant specific data, values, parameters, and equipment specific operational requirements contained in the current TS for Dresden and Quad Cities were retained by the licensee in the TSUP. The staff has accepted this approach.

All changes to the current TS and deviations between the licensees' proposed TS and the STS were reviewed by the staff for acceptability to determine if adequate justification was provided (i.e., plant specific features, retention of existing operating values, etc.).

Administrative Chanagi - Non-technical, administrative changes were intended to incorporate human factor principles into the form and structure of the STS so that they would be easier for plant operation's personnel to use. These changes are editorial in nature or involve the reorganization or reformatting of requirements without affecting technical content of the current TS or operational requirements. Every section of the proposed TS refl.tcts this type of change.

More Restrictive Reouirements - The proposed TSs include certain more restrictive requirements than those contained in the existing TS (i.e., they are more conservative than corresponding requirements in the existing TS or are additional restrictions which are contained in NUREG-0123, but are not contained in the existing TS). Examples of more restrictive requirements include the following:

placing an LC0 on plant equipment that is not required by the present TS to be operable; adding more restrictive requirements to restore inoperable equipment; and adding more restrictive SRs.

less Restrictive Reouirements - Less restrictive requirements are justified on a case-by-case basis as discussed in this SE. When requirements have been shown to provide little or no safety benefit, their removal from the TS may be appropriate.

In most cases, relaxations previously granted to individual plants on a plant-specific basis were the result of (a) genetic NRC actions, and (b) new NRC staff positions that have evolved from technological advancements and operating experience. The Dresden and Quad Cities plant design was reviewed to determine if the specific design basis was consistent with the STS contained in NUREG-0123.

Evaluation Format - The evaluation of Sections 1.0 and 3.0/4.0 has been formatted in the following manner. A table was developed for each TS Section.

The tables are provided as Attachment I to this SE. The tables compare each step of the licensees' proposed TS with the STS.

It should be noted that the tables refer only to step numbers. The specific content of each step (line item) can be obtained by referring to the licensees' July 29, 1992, submittal.

Deviations from the STS are identified in the Deviation / Rationale column.

Where more than a brief explanation is required, the reader is referred to a

l paragraph number in Attachment 2.

Where no technical deviation exists between a statement in the STS and the licensee's submittal, the word NONE appears under Deviation / Rationale.

Deviations the staff finds acceptable include:

(1) the addition of clarifying statements, (2) incorporating changes based on GLs, (3) reformatting multiple steps included under STS action statements into single steps with unique identifiers, (4) retaining plant specific steps, parameters, or values, (5) moving ACTION statements within a TS, (6) moving ACTION statements from an existing TS to form a new TS, and (7) omitting the inclusion of STS steps that are not in existing TS.

2.1 Table 1.1. Section 1.0. Definitions Table 1.1 of Attachment I lists the terms in Section 1.0, " Definitions," for the NRC STS and compares them to the terms proposed for Section 1.0,

" Definitions," of the Dresden and Quad Cities TS. The deviations identified between the STS and the licensee's submittal were either due to plant specific equipment and instrumentation or because the terms are not currently used in the licensee's TS.

The staff finds this acceptable.

Tables 1-1 and 1-2 of Section 1.0, " Definitions," were also reviewed.

One deviation was found in Table 1-1.

The licensee uses the abbreviation E and the term sesquiannual instead of abbreviation R and the term refueling outage as used in the STS.

Since both terms identify the same time interval, approximately eighteen months, the staff finds this equivalent acceptable.

Three deviations were found in Table 1-2.

The licensee references TS 3.10.1 and Special Test Exceptions 3.12.A and 3.12.B.

Special test exceptions 3.12.A and 3.12.B were not submitted with this package, but were received by letter dated September 15, 1992. Technical Specification 3.10.I was submitted by lette-dated February 16, 1993. The contents of TS 3.12.A, 3.12.B and 3.10.1 will be reviewed in a future amendment in the TSUP which deals with that specific section.

The staff has reviewed this section, including each of the above deviations and finds the proposed TS acceptable.

2.2 Table 1.2. 3/4.0 Limitina Condition for Operation: Dresden and Ouad Cities One deviation was identified between the Dresden and Quad Cities LC0 and the STS.

The deviation (3.0.C) represents the retention of an existing plant specification. The licensee retained its requirement that stated when an LC0 is not met, except as provided in the associated ACTION requirements, the plant has to be in hot shutdown in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and cold shutdown within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The STS states that a plant shall be in startup within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, hot shutdown in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold shutdown within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Since this is a retention cf existing requirements and

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the licensee has met the intent of the STS, which is to be in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the staff finds this deviation acceptable.

As indicated above, the licensee has incorporated TS line item improvements contained in GLs into the TSUP. These line item improvements were factored into TSUP to make the proposed TS reflect industry lessons learned in the 1980's and 19a0's and make the proposed TSs adhere more closly to NRC requirements. Below is a discussion of the incorporation of the line item improvements from in the TS.

On June 4, 1987, the NRC staff issued GL 87-09 which addresses three specific problems encountered by licensees regarding the applicability of LCOs and SRs in Sections 3.0 and 4.0 of the STS. One of the problems addressed by GL 87-09 revised STS 3.0.4 (proposed TSUP 3.0.D) by defining when the provisions of 3.0.4 apply (i.e., when the affected ACTION statements permit continued 1

operation for an unlimited period of time, instead of defining when the provisions of 3.0.4 do not apply).

Generic Letter 87-09 recognizes, in part, that Specification 3.0.4 unduly j

restricts facility operation when conformance with the ACTION requirements provide an acceptable level of safety for continued operation in any mode.

For an LCO that has ACTION requirements permitting continued operation for an unlimited period of time, entry into an operation mode or other specified condition of operation mode should be permitted in accordance with those ACTION requirements. The restriction on changes in the operations mode or other specified conditions should apply only when the ACTION requirements establish a specified time interval in which the LCO must be met or shutdown of the facility would be required, or where entry into that operational mode would result in entry into an ACTION statement with such time constraints.

However, the staff position stated in GL 87-09 should not be interpreted as endorsing or encouraging plant startup with inoserable equipment. Generic Letter 87-09 states explicitly that startup wit) inoperable equipment should be the exception'rather than the rule.

Based on our review of the licensee's proposal, we conclude in granting the exceptions to STS 3.0.4. (3.0.D) proposed by the licensee in response to GL 87-09 that:

(1) the remedial measures prescribed by the ACTION statement for each change involving the applicability of the Specification 3.0.4 (TSUP 3.0.0) exception should provide a sufficient level of protection to permit operational mode changes and safe long-term operation consistent with the plaht's UFSAR; and (2) the licensee will establish adequatu administrative controls and procedures which will ensure that startup of the plant with important safety features inoperable will be an infrequent occurrence.

Because no changes are proposed that affect plant configuration, setpoints, operating parameters, or the operator / equipment interface, the NRC staff, therefore, finds the proposed changes acceptable.

Generic Letter 89-14: On August 21, 1989, the NRC staff issued GL 89-14 which removed the 3.25 limit from STS 4.0.2 (4.0.B in TSUP). The staff concluded in GL 89-14 that the removal of the 3.25 limit results in a greater benefit to I

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safety than limiting the use of the 25 percent allowance.to extend the

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v rveillance intervals. The licensee's proposed TS 4.0.B is consistent with i

GL 89-14. Therefore, the staff finds proposed TS 4.0.B to be acceptable.

I The licensee proposed a statement be included in TS Section 4.0.E.6 stating that the inservice inspection program for piping identified in NRC GL 88-01 shall be performed in accordance with the NRC staff positions on schedule, methods, personnel, and sample expansion included in GL 88-01 or in accordance with alternate measures approved by the NRC staff. Since Comed proposed a statement under the Inser. ice Inspection SRs of the TS Section (4.0.E) that is consistent to the TS requirements appreved by the NRC staff for LaSalle County on October 25, 1991, and consistent to the guidance contained in the staff's SE for GL 88-01 issued on August 21, 1990, for Quad Cities and August 23, 1990, for Dresden Station, the staff finds the proposed change acceptable.

Based on the above, the staff finds the TSUP proposed TS for section 3.0/4.0 to be acceptable.

i 2.3.

Bases The staff has reviewed the proposed bases to the TSUP TS.

The licensee has adopted the bases in accordance with the STS content and guidelines.

i Therefore the staff finds the proposed bases acceptable.

3.0

SUMMARY

The licensee's TS will be clearer and easier to use as a result of the adaptation of the STS format and the changes that resulted in additional limitations, restrictions, or changes based on generic guidance.

It is the staff's assessment that the changes proposed in this amendment do not pose any decrease in safety, or an increase in the probability of an analyzed or j

unanalyzed accident. The revised TS changes do not reduce the existing margin of safety set forth by the current TS or as stated in the UFSAR.

Therefore, the staff considers the proposed TS changes to Sections 1.0 and 3/4.0 acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendments.

The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite, and that there is no significant increase in individual or cumulative

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occupational radiation exposure. The Commission has previously issued a i

proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding i

(58 FR 34071). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR SI.22(c)(9).

Pursuant to 10 CFR i

51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

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6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed ebove, t

that:

(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 i

activi+.ies will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public. : Tables of Comparisons Additional Information Principal Contributors:

D. Smith J. Stang Date:

February 16, 1995 4

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T6hS D

STANDARD TECH SPEC TERNS DRESDEN QUAD CITIES gg/,

i Action None Average Planar Exposure None AM'Un!' Ait; ""

Channel Channel Retained Channel Calibration None Channel Check None Channel Functional Test None Core Alteration None kSE$t!kepofE' Smit kepofS' Smit $$g*PhNn! Sty NdN" Critical Power Ratio None Dose Equivalent I-131 None

" Average Disintegration Omitted Omitted Not applicable

nergy hbb$ksp$n!ek$"9 Nre!!N kS!iN~u {$nPu

.iystem esponse $$mfrip 5[agib!n!t NNsStyD hen" None Quad Cities lgion of Rated Thermal None Frequency Notation None Y t ng katio hN$h g

0; sign Limit ggggedFuel Center Sne Melt Identified Leakage None

. solation System Response Omitted Omitted Not reguLred by ime current S

im'iting Control Rod None 5attern garHeatGeneration None cgggARENTHESES CORRESPOND TO PARAGRAPHS IN ATTACHMENT 2 PROVIDING ADDITIONAL ATTACHhENT 1

a TABLE 1.1 (continued)

DEFINITIONS STANDARD TECH SPEC TERMS DRESDEN QUAD CITIES ggf gc System functional None g r g of Limiting Omitted ggeggel None Quad Cities Member of the Public Omitted Omitted Term not used in proposed TS None g; mum Critical Power Off-gas Treatment Omitted Omitted Not in current TS Offsige Dose Calculation Per GL 89-01 Manual Operable-Operability None Operational Mode Operational Mode Retained Operational Condition Omitted Omitted Retained Operational Mode Physics Tests None Pressure Boundary Leakage None i

h5t Per GL 91-08 Process Control Program Per GL 89-01 Purge - Purging Omitted Omitted Not in current TS-Rated Thermal Power None g g P g etion System (4)

(4)

(4)

Reportable Event Reportable Event Retained Reportable Occurrence Omitted Omitted Retained Reportable Event g glicable to Rod Density Omitted None Quad Cities e g gg g ARENTHESES CORRESPOND TO PARAGRAPHS IN ATTACHMENT 2 PROVIDING ADDITIONA l

).

4 TABLE 1.1 (continued)

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DEFINITIONS STANDARD TECH SPEC TERMS DRESDEN QUAD CITIES ggf g g Containment None Shutdown Margin None Site Boundry Omitted Dmitted Not in current TS Solidification Omitted Omitted Per GL 89-01 Source Check None i

Staggered Test Basis Omitted Omitted Not in current TS Seadygtate Retained be}Se$ationRate Thermal Power None Total Peaking Factor Omitted Omitted Not used by fuel vendors g

eBgsSystem Omitted Omitted Not Applicable Ne!E'!Ser $!$

ate Trip System Trip System Retained Unidentified Leakage None Unrestricted Area Omitted Omitted Not in current TS g Exhaust Treatment Omitted Omitted Per GL 89-01 Venting Omitted Omitted Not in current TS f$OekcyiNa$on Fo.EPuieMbbf E ft$he!

!b[f"!!bfhecia1!0[f"!!bhecial E" "

3!Ih.A!!0b!SI.B 3!!h.A!!03SSI.B cig { g g ARENTHESES CORRESPOND TO PARAGRAPHS IN ATTACHMENT 2 PROVIDING ADDITIONAL l

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'1 TABLE 1.2 LINITING CONDITIONS FOR OPERATION STANDARD TS (PROPOSED)

(PROPOSED)

DEVIATION /-

SECTION DRESDEN SECTION QUAD SECTION RATIONALE

• 3/4.0 LIMITING CONDITION FOR OPERATION 3.0.1 3.0.A 3.0.A NONE 3.0.2 3.0.B 3.0.B NONE 3.0.3 3.0.C 3.0.C RETENTION OF EXISTING SPEC.

l 3.0.4 3.0.0 3.0.0 INCORPORATION OF

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GL 87-09 (1) 4.0.1 4.0.A 4.0.A NONE 4.0.2.a 4.0.B 4.0.8 NONE 4.0.2.b 4.0.B 4.0.B INCORPORATION OF GL 89-14 (2) 4.0.3 4.0.0 4.0.0 INCORPORATION OF GL 87-09 (I) 4.0,4 4.0.0 4.0.D INCORPORATION OF GL 87-07 (1) 4.0.5 4.0.E 4.0 E NONE 4.0.5.a 4.0.E.1 4.0.E.I NONE 4.0.5.b 4.0.E.2 4.0.E.2 NONE 4.0.5.c 4.0.E.3 4.0.E.3 NONE 4.0.5.d 4.0.E.4 4.0.E.4 NONE 4.0.5.e 4.0.E.5 4.0.E.5 NONE 4.0.E.6 4.0.E.6 INCORPORATION OF GL 88-01 (3)

• NUMBERS IN PARENTHESES CORRESPOND TO PARAGRAPHS 174 ATTACHMENT 2 PROVIDING ADDITIONAL INFORMATION.

b

O 4 s; bL ADDITIONAL INFORMATION Paragraph Number 1

STS 3/4.0 Commonwealth Edison Company (Comed, the licensee) stated that several modifications were proposed as a result of e

Generic Letter (GL) 87-09. As proposed in GL 87-09, Technical Specification (TS) 3.0.D w;uld provide for entry into applicable operational modes under the provisions of an ACTION statement if the ACTION statement does not

" require a shutdown." Enclosure 1 of GL 87-09 clarified that the " shutdown" referred to for Standard Technical Specification (STS) 3.0.4 meant placing the plant in "a mode or condition of operation in which the LC0 does not t

apply."

l Dresden and Quad Cities have proposed to incorporate this clarification directly into the TS and its Bases. The term shutdown, as used in GL 87-09 proposed STS 3.0.4, could be interpreted in many ways; e.g., reduced power, leave power operation, enter Mode 4 (Cold Shutdown), exit Mode 1-3 (since these are normally the operating modes),

or exit the applicable modes for that TS.

2 STS 4.0.2 i

The licensee incorporated the line item improvement in GL 89-14 which allows the removal of the 3.25 limit on consecutive surveillance interval extensions.

The Bases were also modified to reflect the GL line item improvement.

3 PROPOSED 4.0.E.6 The licensee implemented their commitment to GL 88-01 in Section 4.0.6.E of the proposed TS.

4 STS 1.0 During the staff's review of TSUP Section 1.0 it was noted that the licensee did not incorporate the STS definition for Reactor Protection System (RPS) response time testing.

In subsequent discussions with the licensee, the licensee i

committed to resolve the staff's concern in a future TSUP application.

ATTACHMENT 2

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