ML20079C819

Proposed,Revised Tech Spec Section 1.0, Definitions & Section 3.0/4.0, Applicability

ML20079C819
Person / Time
Site:	Quad Cities
Issue date:	06/20/1991
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20079C817	List: ML20079C816 ML20079C819
References
NUDOCS 9106260152
Download: ML20079C819 (50)

Text

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DPR-29 1.0 DEFINITIONS The succeeding frequently used terms are explicitly defined so that a uniform interpretation of the specifications may be achieved.

A. At L n of the Reactor Core - The act of moving any compone3.t_.in the region a th ore support plate, below the W, and 6g within the shroud. Norma Ep409 g ,, ,

with the control rod drive hydraulic 5 ned as eration. Normal M gp(6op movemen yt of

• s rumentation or movement of the y%

PF .nat-denned as a core alteration.

B. CORE OPERATING LIMITS REPORT - The unit specific document that provides core operating limits for th. current operating reload cycle. These cycle specific core operating limits shall be determined for each reload cycle in accordance with Specification

6. 6. Plant operation within these operating limits is addressed in individual specifications.

I C. Hot Standby - Hot standby means operation with the reactor critif.al, system pressure less than 1060 psig, the main steam isolation valves closed, and thermal power not exceeding 15%.

D. Immediate - Immediate means that the required action will be initiated as soon as practicable considering the safe operation of the unit and the importance of the required action.

E. Inst ent Calibration - An instrument calibration means n instrument signal output so th adjustmen orresponds, within acceptable and accuracy nown value (values) of 6ppb9'g the parameter which the in -

. monitors. Calibration shall encompass the enti rument, in

• q actuation, alarm, or M trip. R , time is not part of the rourin 'nstrument ca4t ration but will be checked once per operating .

F. ITrstrts tional Test - An instrument functional test he injection of a simu a e f -__ . primary sensor to verify the prone.r_.martm response a1atW onJ/-er-4aitialin.g acW G. ITitt+u- Check - An instrument check is qualitative determin ~

of acceptable op ' 'tyJ1' observation of in avior during operation. This determ' lude, where possible, comparison of ment with other independen nrtrtouts m e same variable.

1.0-1 Amendment No. 120 9106260152 910620 PDR ADOCK 05000254 p PDH

QUAD ~ CITIES DPR-29 ] l H. Limiting Conditions fo- Operation _(LCO) - The-14s4Wg-con 45Was.

fee-opentier specify the 99-= eccepteb!e !evels of system pe+formance nece:::ry-t0 :: urc :sfc startup :nd operat4+n-of-4he.

fee 44+ty.-When-these-conditien: are met, the p1ent cea be operetad safely-and-eboormal-situations-can- bc ::fely-contM14ed. (REPLAtra W/STS) the I. Limiting Safe y System tting (LSSS) - The limiting safety system settings are ettings instrumentation which initia the '

automatic protective action at a level such that the will not be exceeded. The region between the ///#,f f*/ 8/[d and these settings represents margin, with normal operation lying below these settings. The margin has been establis ed so t); t with proper operation of the instrumentation, the / //// /4 N will never be exceeded.

K. Logic System functional Test - A logic system functional test means a test of all relays and contacts of a logic circutt from sensor to activated device to ensure all components are /f84/// per design intent. Where po_ssible, action will go to completion, i.e. , pumps will be started and valves op,ened, roe weic merm arem44. ***resrmay,'e4#

'f ?e ? $ "s0 L "r% $ Y M '!A f h % $oc " S I N 4 Y b ?$ $

L. "cdce of-Operation - A,,r,eactor r mode switch selects the proper interlocking for the operating or shutdown condition of the plant.

h h,rcu Following are the modes and interlocks provided:

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1. Shutdown - In this position, a reactor scram is initiated, power to the control rod drives is removed, and the reactor

' protection trip systems have been deenergized for 10 seconds prior to permissive for manual reset.

2 Refuel -_ In this position, interlocks are established so that one control rod only may be withdrawn when flux amplifiers are set at the proper sensitivity level and the refueling crane is not over the reactor. Also the trips from the turbine control valves, turbine stop valves, main steam isolation valves, and condenser vacuum are bypassed. If the refueling crane is over the reactor, all rods must be fully inserted and none can be -

withdrawn.

P

. 3. Startup/ Hot Standby - In this position, .the reactor protection scram trips, initiated by condenser low vace:om and main steamline isolation valve closure, are bypsssed, the low pressure main steam line isolation valve ciosure trip is bypassed,- and the reactor protection system is energized, with IRM and APRM neutron monitoring system trips and control rod .

withdrawal interlocks in service.

4. Run - In this position the reactor system pressure is at or above -

825 psig, and the reactor protection system is energized, with APRM protection and RBM interlocks in service (excluding.the 15% high flux scram).

1.0-2 Amendment No. 114

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r %ve matu rf QUAD ClllES DPR-29 }

H. O erable m A system, subsystem, train, component, or device shall be

,d/p///dflwhenitiscapableofperformingitsspecifiedfunction(s).

Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function (s) are also capable of performing their related support function (s).

N. Operating - Operating means that a system, subsystem, train, coiaper.cnt or device is performing its intended functions in its required manner.

O. Operating Cycle - Interval between the end of one /MddNQ 'aWife#

ra articularunitandtheendofthenextsubsequent/df//1)//

for the same unit.

P. Primary Containment Integrity - Primary containment integrity means that the drywell and pressure suppression chamber are intact and all of the following conditions are satisfied:

1. All manual containment isolation valves on lines connecting to the reactor coolant system or containment which are not required to be open during accident conditions are closed.

2. At least one door in each air lock is closed and sealed.

3. All automatic containment isolation valves are opeeat4e-or-deactivated in the i n hted positicr. en comp //ance wi/h the.

provisions of 3.1.F.

4. All blind flanges and manways are closed.

Q. Protective Instrumentation Definitions

1. Channel - A channel is an arrangement of a sensor and associated components used to evaluate plant variables and produce discrete outputs used in logic. A channel terminates and loses its identity where individual channel cutputs are combined in a logic.

2. Trip System - A trip system means an arrangement of instrument plig/d trip signals and auxiliary equipment required to initiate action to accomplish a protective trip function. A

/MggyTtfe'/may require one or more instrument //p$ rim / trip one or more plant paramet rs in order to signals 4 A/gtedfyft initiatere,1 to,dn' action. Initiati n of ///d(17/

l or the may require the tripping of a sing / ,.

coincidenttrippingoftwo////,lf 1.0-3 Amendment No. 114

QUAD CITIES l DPR-29

3. the protection Protective system whenAction a limit is- reached.

An actionAfinitiatpf f t,# by((#f@Vcan be at i7A -

I the/,Kg///or system level.

4. Protective functiop - A system protective action which results from the g gpla//)f////feif particular @n t condition. of the hf////// monitoring a R. Rated Neutron Flux - Rated neutron flux is the neutron flux that corresponds to a steady-state power level of 2511 thermal megawatts.

S. Rated Thermal Power - Pated thermal power means a steady-state-power level of 2511 thermal regawatts.

T. Reactor Power Operation - Reactor e tion is an with the mode switch in the Sf'l//$$ /fj6fSpower op/ /// or R,6/ ywith position operation the reactor critical and above 1% rated thermal power.

U. Reactor Vessel Pressure - Unless otherwise indicated eactorvessh Coressures intea in the Techndal SpecTTication_ are those measured by the reactor vessel steam space detector.

V. Refueling Outage - Refueling outage is the period of time between the shutdown of the unit prior to a refueling and a startup of the plant subsequent to that refueling.

frequency of testing and surveillance For a the purp// //ose of designating

/If//[f aregularlyscheduled////////f////d/,;however,wher////shallmeane such outages occur within 8 months of the completion of the previous outage, the required-surveillance testing need not be pe//$f//)fif rformed until the next regularly scheduled outage.

W. Safety Limit - The safety _ limits are limits below which the reasonable maintenance of the cladding and primary system are assured. Exceeding such a limit is cause for unit shutdown, and review by the NRC before resumption of unit operation. Operation beyond such a limit may not in itself result in serious consequences, but it indicates an operational deficiency subject to regulatory _ review.

X. Secondary Containment Integrity - Secondary containment integrity means that the reactor building is intact and the following conditions are met:

1. At-least one door in each access opening is closed.

2. The standby gas treatment system is operableg pursuan/ fo

$Pecification s. 7.K-

3. All reactor building automatic ventilation system isolation valves are operable or are secured in the isolated position.

L 1.0-4 Amendment No. 114 l

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DPR-29 Y. down the reactor is in a shutdown condition when the reactor mode is in the Shutdown position and no core alterations are NGd being perfor M0 6 Ip 1. Hot Shutdown means conh"tQns as above, with reactor coolant temperature greater than 212 .

2. Cold Shutdown means conditions as above, wi actor' coolant temperature equal to or less than 212*F.

Z. Simulated Automatic Actuation - Simulated autcmatic actuation means applying a simulated signal to the sensor to actuate the circuit in question.

AA. means the regime between Transition nucleate andBoiling - Transition film boiling. boilipg /Cf//d is the regime in T//rf//////)l which both nucleate and film boiling occur intermittently, with-neither type being completely stable.

BB. Critical Power Ratio (CPR) - The critical power ratio is the ratio of that assembl experience // /// power which causes some point in the assembly to/// $//

condition of nterest as calculated by application of the GEXL correlation (reference NEDO-10958).

CC. Minimum Critical Power Ratio (MCPR) - The minimum iceece critical power ratio corresponding-t+-the most limiting fuel essembly in the-cm shall be the .smalle.sf dPR, tubich ett4f.5 in the ayc.

DD. 3uiveillence InteiVel [ech 5UTVeilli1CE TeQUiiement 5 hell-be L perivemed wiU.in use >gecified 50rveiHence inteisel ith.

t.

' e. A meximum ellewatde-extension-not to exceed-25% ei the g4 surveillance intervel.

b. A total acximum ccabined intervel time fui eny 3 uvusvuulive suive llense inteivel5 601 tv eAsced 3.25 Lime > iiie specittTd

o. .

3urveillance intervel.

Fraction of Limiting Power Density FLPD - Th EE.

power density is the ratio of the //(//lf-)AdM #e fraction-of limiting 8/////M existing at a given location to the design LHGR for_ that bundle-type.

FF. Maximum Fraction of Limiting Power Density (MFLPD) --The maximum fraction of limitin ower densit is the hi est value existing in L the core of the /p// 6f ////f/y/////// (FLPD).

l 1.0-5 Amendment No. 114

1 CITIES R-29 GG. Fraction of Rated Power (FRP) - The fraction of rated power is the ratio of3core thermal power to ///// fff////f//// of 2511 Ffdth.

measured HH. Reportable Event - Any of those conditions specified in Section 50.73 to 10CFR Part 50.

II. Dose Equivalent I-131 - That concentration of I-131 (microcurie /

gram) which alone vould produce the same thyroid dose as the quantity and isotopi mixtur,e of I-131 I-132,1-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation she 'l be those listed in Table III of TID-14844, " Calculation of Distance Factors For Power and Test Reactor Sites."

JJ. Process Control Program (PCP) - Ctnteiss--the--sampl4nganalysis,_.and formulat4sn-determinat4cn by %ich-40MdM4 cat 4en-of-radioactive waites-4 rom-44 quid-systems-is-essuredQcruce w/ ocee-aD KK. Offsite Dose Calculation Manual (0DCM) C1mteint-the-methodology and-pa rameters -u sed-in-the-calcul a t i o n of offsite desee que to radioact4ve-gaseous and 14qu44-ef41uents, and in-the-cal 1!^n e r -

gaseous-and 44 9 uid-ef44uent menitor--alara/ trip- setpoints, pues ev/ee ec)

LL. Channel Functional Test (Radiation Monitor) - Shali-be-the-injection o f-e-si mula ted-+ig na+-i nte-t he-c hen ne4-et-c4es e-to-the-s ense e- a s practieetde-to-ver+fy/17.5-eperatri4-i 4cactions. c Act 40 t-y-tas4 uding-alara-and/-or-tr4p MM. Source Check - The qualitative assessment of instrument response when the sensor is exposed to a radioactive source.

NN. Member (s) of the Public - Shall include all persons who are not .

occupationally associated with the plant. This category does not include employees of the utility, its contractors, or vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for recreational, occupational, or other purposes not associated wiS the plant.

00. Dual Loop Operation (DLO) - /////// ///// ////////$ With both recirculation pumps running.

PP. Single Loop Operation (SLO) - RlIUd/'/$/// ////////f with one recirculation pump running.

1.0-6 Amendment No. 114 I

i SIGNIFICANT HAZARDS CONSIDERATIONS AND ENVIRONMENTAL ASSESSMENT EVALUATION L

PROPOSED TS 1.0 i

' DEFINITIONS' i

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EVALUATIOP ZQB BIGNIFICANT HAZARDS QQFJIDERATIOR PROPOSED SPECIFICATION 1.0 DEFINITIONS The proposed changes provided in snis amendment request are made in order to provide Definitions consistent with later BWR plants and Quad Cities present and past operating practices. The proposed changes also allow implementation of GL 89/01. These changes have been reviewed by Commonwealth Edison and we believe that they do not present a Significant Hazards Consideration. The basis for our determination is documented as follows:

BAEIS, EQB ILQ SIGNIFICANT HAZARDS CONSIDERATION Commonwealth Edison has evaluated this proposed amendtent and datermined that it involves no significant hazards consideration. In accordance with the criteria of 10 CFR 50.92(c) a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility, in accordance with the proposed amendment, would not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated because:

The proposed changes to the definitions are made to clarify present requirements, allow changes that have been adopted at other operating BWRs, promote consistency in understanding of the definition of terms, and to add definitions for terms used in the Quad Cities Technical Specifications that are not currently defined.

The use of the STS and some later operating plants' version of the Core Alteration definition will clearly define when this definition is applicable. Some later operating plants have revised the Core Alteration definition to allow an exclusion to the definition for undervessel removal of incore instrumentation. Incorporating this change to the Core Alteration definition for Quad Cities will allow maintenance to proceed without unnecessary restrictions on plant operation and without impacting core reactivity safety while the plant is in the refuel condition. The use of STS definitions for Channel Calibration, Channel Check, and Channel Functional Test will help to clarify the intent of the present definitions using the " Instrument" terminology. The proposed changes to the Primary Containment and Secendary Containment Integrity requirements.

definitions will clarify present operability The intent of the present definitions is that the Primary Containment Isolation Valves and Standby Gas Treatment Systems be operable pursuant to the requirements of their respective individual specifications. Present definitions could be interpreted to be more restrictive than l

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intended and as such the changes are proposed to clarify present requirements and as such do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change to the definition for Critical Power Ratio (CPR) follows STS guidelines and a later operating plant's version of the CPR definition. To permit the loading of a new fuel design into the QCNPS reactor, the change in fuel design and supporting correlations will have been previously reviewed and approved by the NRC and the limiting transients previously evaluated in the SAR will have been re-analyzed for each reload design. New core operating limits will have been generated and documented in the CORE OPERATING LIMITS REPORT (referenced in the Technical Specifications) to ensure that all safety criteria are met for all analyzed accidents and limiting transients. Therefore, this change does not involve a significant increase in the probability of consequences of any accident previously evaluated.

The changes to the definitions for Fraction of Rated Power and Minimum Critico Power Ratio follow STS guidelines and do not change the tr.W. dical intent of the present definitions. The proposed cham 4ci s the definitions for Process Control Program and Otisitt Dose Calculation Manual follow GL 89/01 guidelines to expand the definitions to more clearly define the content of these documents with the deletion of RETS requirements from the technical specifications. These changes do not involve a significant increase in the probability or consequences of any accident previously evaluated.

The addition of new terms to Section 1.0 provides the user of the technical specifications with easily accessible definitions that are currently accepted by other operating BWRs and are applicable to Quad Cities. New Tables 3-1 and 1-2 allow arrangeinent of presenc Quad Cities requirements or interpretation of requirements into an STS format for ease of use and availability. Proposed Table 1-1, " Surveillance Frequency Notation," uses some of the present Quad Cities interpretations of Surveillance Frequencies and does not relax or modify any existing testing intervals. Proposed Table 1-2,

" Operational Modes," takes present requirements that are located in individual specifications and uses an STS format for arrangement of these provisions. Present temperature limits for Operational Modes are retained except for Refuel where the STS limit of 5 140 0 F is adopted. Footnotes are added to provide clarification and to allow exceptions to Mode switch position where needed to allow for necessary testing and other operations. Since the proposed addition of Tables 1-1 and 1-2 retains present operating restrictions and testing allowances or adopts proven STS guidelines that are applicable to Quad Cities, there is no increase in the probability or consequences of an accident previously evaluated.

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4 The hpplicable provisionn of present Definition 1.0.D0,

" Surveillance Interval" are being moved and retainod in proposed Specification 4.0.B after consi ..,.ng implomontation of Generic Letter 89-14. The present provisions of Dofin4. tion 1.0.Y, " Shutdown," are proposed to bo moved to now Table 1-2.

The propound movemont of theso requirements provides a more user friendly document and retains necessary limiting provisions.

2) create the possibility of a now or different kind of accident from any previously evaluated because The proposed changos leave intact present operating philosophy and only implomont now provisions where necessary to clarify and ensure that present allowancou are understood and maintained. The proposed excsption to the Core Alteration definition will allow undervossol replacement of incore instruments without considering this an alteration of the core. Due to the small amount of fissionable material in these instruments, their movement cannot create the possibility of a now or different kind of accident from any previously evaluated for nuclear safety.

The change from the " Instrument" philosophy to the " Channel" philosophy for calibrations, checks and functional tests rovidos clarification of present wording and intent. The STS Nchannol" philosophy is bolng used at Quad cities in many present applications and this technical specification change will ensure its consistent usu for applicable testing functions.

The proposed changes to the Primary containment and Secondary Containment Integrity definitions are clarifications at intent with respect to operability provisions for Primary ntainment Isolation Valvos and Standby Gas Treatment Systems Primary Containment and Secondary Containment Integrity requirements are considered to be maintained while equipment and systems are in the Action statements of Specifications 3.7.F and 3.7.K. The individual equipment and system specifications contain allowed outage provisions to ensure that operability I

is maintained within defined time limits which are considered to be sufficiently short in duration, suc,h that impact is minimal to Primary or Secondary Containment Integrity I

considerations. The proposed changes do not change system operability requirements and as such do not create the possibility of a new or different kind of accident from any previously evaluated.

Use of a more generic reference " applicable NRC-approved critical power correlation" in the critical Power Ratio definition in place of a reload specific correlation like "GEXL" will noc change the present intent of the definition but only preclude the necessity to revise the Critical Power

l Ratio definition every time there are minor changes in the fuel manufacturer's critical power correlations to support their new fuel design. Provided that the changes to the critical power correlation are reviewed and approved by the NRC, no new or different accident, from any previously evaluated, is created by this broado't definition. Therefore, I this change cannot create the possibility of a new or i different kind of accident from any previously evaluated.

l The changes to the definitions for Fraction of Rated Power and Minimum Critical Power Ratio do not change present intent and are made to clarify present requirements. The changes to the definitions for PCP and ODCM are expansions of present provisions in order to implement the provisions of GL 89/01.

Due to the nature of these changes, ticy cannot create the possibility of a new or different kind of accident.

The addition of new definitjons to the technical specifications is an enhancement to present provisions. STS guidelines are used for the new definitions and have been evaluated and found to be in agreement with present usage at Quad Cities. New Tables 1-1 and 1-2 follow an STS format for implementing present Quad Cities surveillance Frequencies and ,

Operational Modes. Present operational Mode restrictions on reactor coolant temperature are retained for Operational Modes 1, 2, 3, and 4; and, are changed to STS guidelines for operational Mode 5. Present reactor modo switch position restrictions are retained by including necessary notes to allow testing and otner operations. Since either present provisions are retained or present interpretation of requirements are maintained, the changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3) :nvolve a significant reduction in the margin of safety because:

The proposed changes to the definitions provide clarifications, implement proven changes from operating BWRs that are applicable at Quad cities and include present provisions and interpretations pres,ented in STS format.

Present margins of safoty are retained and improved by clarifying requirements that are subject to interpretation or are not presented in an eacy to understand format.

The proposed change to the Core Alteration definition does not affect n'aclear safety since replacement of incore instrumentation under the vessel has little or no measurable impact on core reactivity. The change from the " Instrument" to the " Channel" philosophy for calibration, checks, and functional tests provides clarification of present intent.

Clarifications to the definitions for Primary and Secondary Containment Integrity are made to prevent misinterpretation of intent of the present requirements and do not reduce any

• margin of safety. The proposed revision to the definition of L Critical Power Ratio will merely redefine, in broader terms, '

the definition of critical power ratio and will not cause a change in any margin of safety. Each fuel reload analyses will continue to ensure that the fuel system design nuclear thermal design,l origina core a/ nalysis hydraulic design remain andfor valid thethe conclusions, accidents of and the limiting transients previously evaluated in the EAR. The changes to the definitions for Fraction of Rated Power and Minimum Critical Power Ratio are clarifications of present "

requirements that do not change present technical intent. The changes to the definitions for PCP and ODCM more clearly define the contents of these documents with the implementation of GL 89/01 provisions.

As such these changes cannot reduce any margin of safuty.

The new definitions added to Section 1.0 apply to terms in current use in the Quad cities Technical Specifjcations and this addition improves understanding of requirements. New Tables 1-1 and 1-2 follow the STS in format with notations and operational modes based on present Quad cities Technical Specification-requirements, interpretation of requirements, or STS guidelines that are applicable to Quad Cities. Table 1-2 notes follow present Quad cition allowances or interpretation of allowances and follow later operating plants and STS guidelines. Since the proposed changes implement present Quad cities allowances in an STS format and follo' proven allowances at other operating plants that are-acceptable for use at. Quad Cities, there is no reduction in any margin of safety. t i

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l KNYlBQHliENTAL ASEEDEJiERI EVALUATION PROPOSED SPECIFICATION SECTION 1.0 DEFINITIONS Commonwealth Edison has evaluated the proposed amendment in accordance with the requirements of 10 CFR 51.21 and has determined that the amendment meets the requirements for categorical exclusion as specified by 10 CFR 51.22(c) (9) .

Commonwealth Edison has determined that the amendment involves no significant hazards consideration there are no significant change in the types or significanb increase in the amounts of any effluent that may be released o ffsite, and there is no significant increase in individual or cumulative occupational radiation exposure.

The proposed amendment does not modify the existing facility and does not involve any new operation of the plant.

As such, the proposed amendment does not involve any change in the type or significant increases in ef fluents, or increase individual or cumulative occupational radiation exposure. The proposed amendment to Section 1.0,

" Definitions" contain administrative changes such as arranging the definitions in alphabetical order and assigning numerical designation. The proposed amendment updates the existing definitions to be consistent with carrent industry standards and adds new definitions which are provided in the Standard Technical Specifications and later operating plants' Technical Specifications.

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2 QC-1/ QC-2 DIFFERENCES TS 1.0

' DEFINITIONS' l

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, O COMPARISON OF UNIT 1 AND UNIT 2 TECHNICAL 8PECIFICATIONS FOR THE IDENTIFICATION OF TECHNICAL DIFFERENCES SECTION 1.0 DEFINITIONS Commonwealth Edison has conducted a comparison review of the Unit 1 and Unit 2 Technical Specifications to identify any technical differences in support of combining the Technical Specifications into one document. The intent of the review was not-to identify any differences in presentation style (e.g. table formats, use of capital letters, etc.) or punctuation but rather to identify areas which the Technical Specifications are technically different.

The-review of.Section 1.0, " Definitions" did not reveal any technical differences. The only difference identified was-in the definition, V. Refueling Outage.

Descriotion V. R3 fueling outage Unit 1: Refueling outage is the period of time between the shutdown of the unit prior to a refueling and a startup....

Unit 2: Refueling outage is the period of time betwoon the shutdown.of the unit prior to a refueling and the startup...

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l QUAD CITIES 1 NUCLEAR POWER STNI' ION ,

TECHNICAL SPECIFICATION UPGRADE PROGRAM

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- t*.7 PROPOSED AMENDMENT SECTION 3.0/4.0 " Applicability"

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1 EXECUTIVE

SUMMARY

Proposed Changes to TS 3,0/4.0

' APPLICABILITY'

EXECUTIVE EEKMARY QUAD CITIES TECHNICAL BPECIFICATION UPGRADE PROGRAM The Quad Cities Technical Specification Upgrade Program was conceptualized in response to lessons learned from the Dresden Diagnostic Evaluation Team inspection and the frequent need for Technical Specification interpretations. A comparison of the existing Quad Cities Technical Specification and Standard Technical Specifications and later operating plants' Technical Specification provisions was conducted to identify potential improvements in clarifying requirements and to identify requiremonts which are no longer consistent with current industry practicos.

The comparison review identified approximately one-hundred and fifty suggested improvements. The Technical Specification Upgrade Program was not intended to be a complete adoption of the Standard Technical Specifications.

Overall, the Quad Cities custom Technical Specifications provide for safe operation of the plant and, therefore, only a upgrade was deemed appropriato.

The comparison study revealed a mix of recommended upgrades which included the relaxation of cortain existing Technical Specification requirements, the addition of surveillances, the comoval of allowances which would no longer be allowed under new plant licensing, and better definition of appropriate action requirements in the event a Limiting Condition for Operation cannot be met. The Technical Specification Upgrade program also implements NRC recommended line item improvements to the Technical Specifications which were issued under Generic Letters.

In response to an NRC recommendation, the Unit 1 and Unit 2 Technical Specifications are combined into one document. To accomplish the combination of the Units' Technical Specifications, a comparison of the Unit 1 and Unit 2 Technical Specifications was performed to identify any technical differences. The technical differences are

= identified in the proposed amendment package for each section.

The Tcchnical Specification Upgrade Program was identified as a Station Top Priority during the development of the Quad Cities Station's performance Enhancement Program (PEP) . The Technical Specification Upgrado Program's goal is to provide a better tool to Station personnel to implement their responsibilities and to ensure Quad Cities Station is operated in accordance with current industry practices. The upgraded specifications provide for more safe and reliable operation of the plant. The program improves the operator's ability to use the Technical Specifications by more clearly defining Limiting Conditions for Operations and required actions. The most significant improvement to the specifications is the addition of equipment operability requirements during shutdown conditions.

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EXECUTIVE

SUMMARY

(continued)

PROPOSED CHANGES TO TECHNICAL BPECIFICATION BECTION 3.0/4.0, "APPLICABILITYH Present Section 3.0, " Limiting Condition for Operation" contains two Specifications. Limiting condition for Operation (LCO) 3.0.A addresses the action to be taken if an LCO cannot be satisfied. LCO 3.0.B delineates the additional conditions which must be satisfied to permit continued operation when a normal or emergency power source is not operable. Neither of these Specifications contains upper level provisions governing the use and applicability of Surveillance Requirem7nts for the individual Specifications.

The proposed amendment retains the provisions of the Specification 3.0.A and 3.0.D and adds requirements not currently delineated in the Specifications. The general content of these new provisions are accepted as standard operating practice at later boiling water reactor plants.

The proposed amendment to Specification 3.0/4.0 are intended to accomplish the following:

- Provides direction regarding LCO compliance during specific reactor modes and the associated Action requirements upon failure to meet an LCO.

- Defines noncompliance with a Specification and the required actions associated with restoration of an LCo.

- Defines the necessary actions for those circunstancoc not directly provided for in the Action statement of a Specification.

- Provides guidance to define when entry into an Operational Mode or other specified condition is allowed if the plant is operating under the action provisions of an LCO.

- Specifies when Surveillance Re@irements shall be met and the time interval allowed for performing Surveillance Requirements and, defines a failure to satisfy a Surveillance Requirement.

- Specifies that entry into Operational Modes or other specified ccaditions shall not be made unless the Surveillance Requirement associated with the LCO have been performed within the applicable surveillance interval or as otherwise specified.

- Establishes Inservice Inspection and Inservice Testing of ASME Code Class 1, 2, and 3 components.

SUMMARY

OF CHANGES Proposed TS 3.0/4.0

' APPLICABILITY

• MiMARY QE 9EANGES PROPOSED SPECIFICATION 3.0/4.0 APPLICABILITY The following changes have been identified for Quad-Cities Unit 1 Technical Specifications as follows:

Item 1:

Pace 1.0-5. DPR-29 Dolote Definition 1.0.DD on Surveillance Interval and incorporate these requirements into newly proposed Surveillance Requirement 4.0.B.

Item 2:

Pages 3.0/4.0-1 ,qnd 3.0/4.0-2, DPR-29 Rewrite Section 3.0/4.0 Limiting Conditions for Operation to include the following requirements:

a) Add new 3.0.A to delineate when each Specification is applicable and to state that when a LCo is not met, the associated Action requirements shall be met.

b) Add new 3.0.B to define the conditions necessary to constitute compliance with the terms of an LCO and associated Action requirements.

c) Rewrito present 3.0.A and change its number to 3.0.C. The proposed change will rewire action to be initiated within one hour if a LCO is not met and retains the present provision of being in at least Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and at least 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 />.

d) Ch:...ge present 3.0.B to 3.0.E and reword for clarification, e) Add new 3.0.D to provide requirements to allow entry into operational Modes or other specified conditions when in the Action provisions of a LCo.

f) Add new 4.0.A to provide that surveillance activities necessary to ensure the LCO are met during the reactor modes or other conditions for which the LCO is applicable.

g) Add new 4.0.B incorporating the provisions of Definition 1.0.DD and Generic Letter 89/14. Also add that exceptions to these Surveillance Requirements must be stated in individual Specifications.

I h) Add new 4.0.C to set forth the criteria for determination of compliance with the operability requirements of the LCo.

1) Add new 4.0.D to provido provisions for limiting entry into an operational Mode or other specified condition when I Surveillance Requirements have not been met for a LCO.

j j) Add new 4.0.E to specify Inservice Testing and Inspection provisions.

Item 3:

Engga B 3. 0/4. 0-1 through D 3. 0/4. 0-9. DPR-29 Add bases for the new 3.0/4.0 LCO and Surveillance Requirements.

Incorporate the provisions of Generic Letters 87/09 and 89/14.

{~

DESCRIPTION OF CHANGES Proposed TS 3.0/4.0

' APPLICABILITY'

y QEACRIPTION QE PROPOSED AM HDMENT B1QE H PROPOSED SPECIPICATION 3.0/4.0 APPLICABILITY  !

Present Section 3.0 Limiting Condition for Operation contains two Specifications. LCO 3.0.A addresses the action to be taken if a LCO cannot be satisfied because of circumstances in excess of those listed in the Specification. LCO 3.0.B delineates what additional conditiuns must be satisfied to permit operation to continue, consistent with the LCOs for power sources, when a normal or emergency power source is not operable. The present 3.0 Specifications are lacking in content and do not contain upper level provisions governing the use and applicability of '

Surveillance Requirements for the individual Specifications.

This proposed amendment retains the provisions of present Specifications 3.0.A and 3.0.B while adding requirements not currently delineated in the Specifications. The general content of these new provisions are accepted as standard operating practice at later.BWRs and are intended to provide additional guidance at Quad Cities Nuclear Station in order to avoid misinterpretations that may lead to unnecessary restrictions on plant operation. Some of the proposed changes are modeled after those proposed in Generic Letters 87/09 and 89/14.

An item by item description of the proposed-changes requested is provided below. -The Summary of Changes section can be referred to in order to reference back to a given change and its affected page.

Item 1 This item deletes present Definition 1.0 DD on Surveillance Interval and incorporates the provision for maximum allowable extension not to exceed 25% in newly proposed Specification 4.0.B.

The Definition 1.0.DD provision for tae combined time interval for any 3 consecutive surveillance intervals has been deleted in accordance with Generic Letter 89/14 guidelines.

Item 2 The proposed e.dditions and changes to Specifications 3.0/4.0 are

-intended to accomplish the following:

.LQ2 3.0. A -- Provide written direction' such that a - LCO must be complied with during specified recctor modes or other specified conditions and u on failure to meet a LCO, the associated Action requirements sha 1 be met.

1&Q 3.0.B - Define when noncompliance with a Specification exists.

Noncompliance exists when_the LCo and Action provisions are not

=- _ - _ _ _ _ - - - . - - . . -

met within specified time inte rvals . Also 3.0.B specifies that if the LCO is restored completion of the Action requirements is not required thus allowing a halt to testing, plant shutdown or other i Action provisions in progress.

LCQ 3.0.C - Rewrito present 3.0.A to more clearly define the actions necessary to be taken for those circumstances not directly provided for in the Action statements of a Specification. Changes to present LCO 3.0.A will improve this Specification by requiring action within one hour to place the unit in a reactor mode or other condition in which the specification does not apply.

Retained from present Specification 3.0.A are the provisions to be in at 1 cast Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and at least 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 />, after the one hour allowance. These provisions will help ensure that steps are being taken in a timely manner to place the plant in a reactor mode or

, other condition where the inoperable equipment is not required.

l Any exceptions to these new provisions must be stated in the I individual Specifications and thus must have prior NRC approval.

LCQ 3.0.D - Provide written guidance to define when entry into an Operational Mode or other specified condition is allowed if the plant is operating with systems or equipment under the action l provjsions of a LCO. Entry into an Operational Mode or other i specified condition is allowed in accordance with the action requirements when conformance to the action requirements permits continued operation of the facility for an unlimited period of time. Otherwise, entry into an Operational Mode or other specified condition shall not be made when the conditions for the LCO are not met and the associated action requires a shutdown if they are not met within a specified time interval. Any exceptions to these provisions must be stated in the individual specifications.

LCQ 1xQtE - Incorporate the provisions of present LCO 3.0.B. The only changes involve rewording for clarification purposes. No technical changes are prop osed.

Surveillance Reauirement A2f2A - Specify when Surveillance Re@irements shall be met. Unless otherwise stated in an individual Specification, the Surveillance Rep irements shall be met during the reactor mode or other specified conditions for the LCO. Also to help prevent misinterpretation, a statement is provided such that Surveillance Requirements do not have to be performed on inoperable equipment.

Surveillanqn Recuirement 4.0.B - Indicate in Section 4.0 the time interval allowed for performing Surveillance Requirements. The provision of Definition 1.0.DD that specifies a maximum allowable extension of 25% of the surveillance interval is included in 4.0.B. On August 21, 1989, the NRC Staff issued Generic Letter 89/14 which removes the 3.25 limit from Specification 4.0.B (4.0.2 in the Generic Letter) . The NRC Staff concluded in this letter that the removal of the 3.25 limit results in a greater benefit to l

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l safety than limiting the use of the 25% allowance to extend surveillance intervals. Commonwealth Edison has evaluated the provisions of this Generic Letter and concluded that incorporation at Quad Cities Units 1 and 2 will represent an improvement over present requirements. An/ exceptions to these provisions must be stated in the individual Specification and thus must be approved by the NRC. This exception policy will prevent conflicting requirements in the specifications where exceptions are allowed such as present Definition 1.0.V on Refueling Outage.

Surveillance Reauirement 4.0.C - Define the meaning of f ailure to satisfy a Surveillance Requirement. This failure results in a failure to meet the opet' ability requirements for a LCO. The time ,

limits of the Action re@irements are initiated at the time it is identified that a Surveillance Requirement has not been performed within the maximum allowed surveillance interval. The Action may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit completion of the surveillance when the allowable outage time limits of the Action requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Any exceptions to those provisions must be stated in the individual Specifications and thus must have prior NRC approval.

Survei:.langa Reauirement 4.0.D - Specify that entry into Operatnonal Modes or other specified conditions chall not be made unless the Surveillance Requirements associated with the LCO have been performed within the applicable surveillance interval or as otherwise specified. This specification helps to ensure equipment operability when required by the Technical Specification Applicability statement. This requirement does not prevent passage through or to Operational Modes as required to comply with action requirements. Exceptions to these requirements must be stated in the individual specifications.

Surveillance Eqquj rement 4.0.E - Establishes the requirement that Inservice Inspection of ASME Code Clars 1, 2, and 3 components and Inservice Testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with a periodically updated version of Section XI of the ASME Boiler and pressure Vessel Code and Addenda as required by 10 CFR 50.55a. Under the terms of this specification, the more restrictive requirements of the Technical Specifications take precedence over the ASME Boiler and pressure vessel Code and applicable Addenda.

Item 2 Add bases for the new 3.0/4.0 LCO and Surveillance Requirements.

Incorporate the provisions of Generic Letters 87/09 and 89/14.

SUMMARY

On June 4. 1987 the NRC Staff issued Generic Letter 87/09 dealing with recent initiatives undertaken by the NRC Staff and the nuclear industry to improve Technical Specifications. The generic letter provided guidance for three specific problems

. l 1,  !

i encountered with the general requirements on the applicability of LCO and Surveillance Requirements in Moctions 3.0 and 4.0. The generic letter included tho NRC modified version of Section 3.0

, and 4.0 of thu BWR Standard Technical Specification (STS), and provided the staff's updated version of the BWR STS Bases for these sections. The generic letter stated that the NRC staff has concluded that those modifications will improve the Technical Specifications for all plants, and encouraged licenscos to propose cianges to their Technical Specifications consistent with the yenoric letter guidance. Commonwealth Edison has reviewed the generic letter with its onclosures and concluded that the proposed modifications as proposed in this amendment are an improvement over present Quad cities Technical Specifications.

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i

1 PROPOSED TECH SPEC TS 3.0/4.0

' APPLICABILITY' l

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QUAD CITIES UNITS 1 & 2 DPR-29 & DPR-30  !

3.0/4.0 APPLICABILITY 3.0 LIMITING CONDITIONS FOR OPERNI.ON A. Compliance with the LIMITING CONDITIONS FOR OPERATION contained in the succeeding Specifications is required during the reactor OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the LIMITING CONDITIONS FOR OPERATION, the associated ACTION requirements shall be met.

B. Noncompliance with a Specification shall exist when the requirements of the LIMITING CONDITION FOR OPERATION and associated ACTION requirements are not met within the specifie. time intervals. If the LIMITING CONDITION FOR OPERATION is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

C. When a LIMITING CONDITION FOR OPERATION is not met, except as provided in the associated ACTION requirements, within one hour ACTION shall be initiated to place the unit in a reactor OPERATIONAL MODE or other cpecified condition in which the Specification does not apply by placing it, as applicable, in:

1. At least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and

2. At least 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 />.

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION.

may be taken in accordance with the specified time limits as measured from the time of failure to meet the LIMITING-CONDITION FOR OPERATION. Exceptions to these requirements are stated in the individual Specifications.

This Specification is not applicable in COLD SHUTDOWN or REFUELING.

D. Entry into an OPERATIONAL MODE or other specified condition shall not be made when the conditions for the LIMITING CONDITIONS FOR OPERATION are not met 3.0/4.0-1

l QUAD CITIES UNITS 1 & 2 DPR-29 & DPR-30 and the associated ACTION requires a shutdown if they are not met within a specified time interval.

Entry into an OPERATIONAL MODE or other specified condition may be made in accordance with the ACTION requirements when conformance to them permits continued operation of the facility for an unlimited period of time. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements. Exceptions to these requirements are stated in the individual Specifications.

E. When a system, sobsystem, train, component, or device is determined to have an inoperable emergency power source or an inoperable normal power source, the system, subsystem, train, component, or device may be considered OPERABLE -for the purpose of satisfying the requirements of its applicable LIMITING CONDITION FOR OPERATION, provided: (1) its corresponding normal or emergency power source is OPERABLE, and (2) all of its redundant system (s),

subsystem (s), train (s), component (s), and device (s) in the other division are OPERABLE, or likewise satisfy the requirements of this specification.

Unless both conditions (1) and (2) are satisfied, the unit shall be placed in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and in at least COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This Specification is not applicable in COLD SHUTDOWN or REFUELING.

3.0/4.0-2

QUAD CITIES UNITS 1 & 2 DPR-29 & DPR-30 4.0 SURVEILLANCE REQUIREMENTS A. Surveillance Requirements shall be met during the reactor OPERATIONAL MODES or other conditions specified for individual LIMITING CONDITIONS FOR OPERATION unless otherwise stated in an individual I Surveillance Requirement. Surveillance requiremento do not have to be performed on inoperable equipment.

B. Each Surveillance Requirement shall be performed ,

within the specified time interval with a maximum t allowable extension not to exceed 25% of the -

surveillance interval. Exceptions to this  :

-requirement _are stated in the individual specifications.

C. Failure to satisfy a Surveillance Requirement within the maximum allowed surveillance interval, defined by Specification 4.0.B, shall constitute a failure to meet the operability requirements for a LIMITING CONDITION FOR OPERATION. The time limits of the ,

ACTION requirements are initiated at the time it is identified that a Surveillance Requirement has not been performed within the maximum allowed surveillance interval. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to p a it the completion of the surveillance when the all wable outage time limits of the ACTION requiremenso are

-less than-or equal to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Exceptions to these requirements are stated in the individual Specifications.

D. Entry into an OPERATIONAL MODE or other specified applicable condition shall not be -made unless the Surveillance Requirement (s) associated with the LIMITING CONDITION FOR OPERATION have been performed within the applicable surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as comply-- with ACTION requirements.

required to

! Exceptions to these requirements-are stated in tha individual Specifications.

E,. Surveillance Requirements : for inservice inspection and testing of ASME Code Class 1, 2, and- 3 components shall be applicable as follows:

1. Inservice Inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME 3.0/4.0-3

- .~ . L , , , - ....~..-..__~..._m_,. _ . - _ . , , . _ _ . , _ . . . . . . . . _ _ . . _ . . . _ . . . . . _ . _ _ . - . _ . . . _ _ . - - . . _ _ _ . . . _ _ _

I QUAD CITIES UNITS 1 & 2 DPR-29 & DPR-30 Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g) (6) (1) .

2. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in those Technical Specifications:

ASME Boiler and Pressure Vessel Code and applicable Required Frequencies Addenda terminology for for performing inservice inspection and inservice inspection testina cLgtivities ansLtestina activities Weekly At least once per 7 days Monthly At least once per 31 days Quartcrly or every 3 months At least once per 92 days Semiannually or overy 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days

3. The provisions of Specification 4.0.B are applicable to the above required frequencies for performing inservice inspection and testing activities.

4. Performance of the above inservice inspection  ;

and testing activities shall be in addition to other specified Surveillance Requirements.

5. Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirements of any Technical Specification.

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3.0/4.0-4 l

QUAD CITIES UNITS 1 &2 DPR-29 & DPR-30 3.0 LIMITING C_QHDITIONS FOR OPERATION BASES Specificatione 3.0.A through 3.0.E establish the general requirements applicable to LIMITING CONDITIONS FOR OPERATION (LCO). These requirements are based on the requirements for LIMITING CONDITIONS FOR OPERATION stated in the Code of Federal Regulations, 10 CFR 50.36(c)(2):

" Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specification until the condition can be met."

3.0.A Specification 3.0. A establishes the applicability of each specification in terms of defined reactor OPERATIONAL MODES or other specified condition as the requirement for when conformance to the LIMITING CONDITION FOR OPERATION is required for safe operation of the facility. The ACTION requirements establish those remedial measures that must be taken within specified time limits when the requirements of a LCO are not met. It is not intended that the shutdown ACTION requirements be used as an operational convenience which permits (routine) voluntary removal of a system (s) or component (s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

There are two basic types of ACTION requirements.

The first specifies the remedial measures that parmit continued operation of the facility which is not further restricted by the time limits of the ACTION requirements. In this case, conformance to the ACTION requirements provides an acceptable level of safety for unlimited continued operation as long as the ACTION requirements continue to be met. The second type of ACTION requirement specifies a time limit in which conformance to the conditions of the LCO must be met. This time limit is the allowable outage time to restore an inoperable system or component to OPERABLE status or for restoring parameters within specified limits. If these ACTIONS are not completed within the allowable outage time limits, a shutdown is required to place the facility in a reactor OPERATIONAL MODE or other specified condition in which the specification no B 3.0/4.0-1

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QUAD CITIES UNITS 1 & 2 DPR-29 & DPR-30 longer applies.

The specified time limits of the ACTION requirements are applicable from the point in time it is identified that a LCO is not met. The time limits of the ACTION requirements are also applicable when a system or component is removed f rom service for surveillance testing or investigation of operational problems. Individual specifications may include a specified time limit for the completion of a surveillance Requirement when equipment is removed from service. In this case, the allowable outage time limits of the ACTION requirements are applicable when this limit expires if the surveillance has not been completed.

When a shutdown is performed to comply with ACTION requirements, the plant may enter a reactor OPERATIONAL MODE or plant condition in which a new specification becomes applicable. In this case, the time limits of the ACTION requirements would apply from the point in time that the new specification becomes applicable if the requirements of the LCO are not mot.

3.0.B Specification 3.0.B establishes that noncompliance with a specification exists when the requirements of the LCO are not met and the associated ACTION requirements have not been implemented within the specified time interval. The purpose of this specification is to clarify that (1) implementation of the ACTION requirement within the specifled time interval constitutes compliance with a specification and (2) completion of the remedial measures of the ACTION requirements is not required when compliance with a LCO is restored within the time interval specified in the associated ACTION requirements.

3.0.C Specification 3.0.C establishes the shutdown ACTION requirements that must be implemented when a LCO is not act and the condition is not specifically addressed by the associated ACTION requirements.

The purpose of this specification is to delineate the t1*e limits for placing the unit in a safe shutdown condition when plant operation cannot be maintained within the limits for safe operation defined by the LCO and its ACTION requirements. It is not intended to be used as an operational convenience which permits (routine) voluntary B 3.0/4.0-2 1

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QUAD CITIES UNITS 1&2 DPR-29 & DPR-30 removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or conponents being inoperable. One hour is allowed to prepare for an orderly shutdown before initiating a c1ange in plant operation.

This time permits the operator to coordinate the reduction .n electrical generation with the load dispatcher to ensure the stability and availability of the electrical gria. The time limits specified to reach lower conditions of operation permit the shutdown to proceed in a controlled and orderly manner that is well within i' > specified maximum cooldown rate and within tr 'oldown capabilities of the facility assuming e minimum required equipment is OPERABLE. reduces thermal stresses on components of th mary coolant system and the potential for a plant transient that could challenge safety systems under conditions for which this specification applies.

If remedial measures permitting limited continued operation of the facility under the provisions of the ACTION requirements are completed, the shutdown may be terminated. The time limits of the ACTION requirements are applicable from the point in time there was a failure to meet a LCO. Therefore, the shutdown may be terminated if the ACTION requirements have been met or the time limits of the ACTION requirements have not expired, thus providing an allowance for the completion of the required ACTIONS.

The time limits of Specification 3.0.C allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the plant to be in COLD SHUTDOWN when a shutdown is required during power operation. If the plant is in a lower condition of operation when a shutdown is reqaired, the time limit for reaching the next lower reactor OPERATIONAL MODE applies.

However, if a lower condition of operation is reached in less time than allowed, the total allowable time to reach COLD SHUTDOWN, or other reactor OPERATIONAL MODES, is not reduced. For example, if HOT SHUTDOWN is reached in 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, the time allowed to reach COLD SHUTDOWN in the next 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> because the total time to reach COLD SHUTDOWN is not reduced from the allowable limit of 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Therefore, if remedial measures are completed that B 3.0/4.0-3

QUAD CITIES UNITS 1 & 2 DPR-29 & DPR-30 would permit a return to power operation, a penalty is not incurred by having to reach a lower condition of operation in less than the total timo allowed.

The same principle applies with regard to the allowable outage timo limits of the ACTIOli requirements, if compliance with the ACTION requirements for one specification results in entry into a reactor OPERATIOliAL MODE or other condition of operation for another specification in which the requirements of the LCO are not mot. If the new specification becomes applicable in less time than specified, the difference may be added to the allowable octage time limits of the second specification. Iloweve r, the allowable outage tino limits of ACTION requirements for a higher condition of operation may not be used to extend the allowable outage time that is applicable when a LCO is not met in a lower condition of operation.

The shutdown requirements of Specification 3.0.C do not apply in COLD SHUTDOWN or REFUELING, because the ACTIO!I requirements of individual specifications define the remedial measures to be taken.

3.0.D Specificetion 3.0.D establishes limitations on a change in OPERATIONAL MODES when a LIMITING CONDITION FOR OPERATION is not met. It precludes placing the facility in a higher MODE of operation when the requirements for a LIMITING CONDITION FOR OPERATION are not met and continued noncomp1 lance to these conditions would result in a shutdown to comply with the ACTION requirements if a change in MODES Were permitted. The purpose of this specification is to ensure that facility operation is not initiated or that higher MODES of operation are not entered when corrective ACTION is being taken to obtain compliance with a specification by restoring equipment to OPERABLE status or parameters to specified limits. Compliance with ACTION requirements that permit continued operation of the facility for an unlimited period of time provides an acceptable level of safety for continued operation without regard to the status of the plant before or after a change in OPERATIONAL MODES. Therefore, in this case, entry into an OPERATIONAL MODE or other specified condition may be made in accordance with the provisions of the ACTION requirements. The provisions of this specification should not, D 3.0/4.0-4 i

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l QUAD CITIES UNITS 1 &2 DPR-29 & DPR-30 however, be interpreted as endorstng the failure to exercise good practice in restoring systems or components to OPERABLE status before plant startup.

When a shutdown in required to comply with ACTION requirements, the provisions of Specification 3.0.D do not apply because they would delay placing the facility in a lower MODE of operation.

3.0.E Specification 3.0.E delineates what additional conditions must be satisfied to permit operation to continue, consistent with the LIMITING CONDITION FOR OPERATION statements for power sources, when a normal or emergency power source is not OPERABLE.

Power sources are defined as AC Auxiliary Electrical Systems as defined in Section 3.9.A. It specifically prohibits operation when one division is inoperable because its normal or emergency power source is inoperable and a system subsystem, train, component or device in another division is inoperable for another reason.

The provisions of this specification permit the LIMITING CONDITION FOR OPERATION statements associated with individual systems, subsystems, trains, components or devices to be consistent with the LIMITING CONDITION FOR OPERATION statements of the assouinted electrical power source. It allown operation to be governed by the time limits of ACTION statements associated with the LIMITING CONDITION FOR OPERATION for the normal or emergency power source, not the indi"idual ACTION statements for each system, subsystem, train, component, or device that in determined to be inoperable solely because of the inoperability of its normal or energency power source.

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h-.sa ,.a.: A _.24< + 1A- rA --_a -.,,a,. -- 4--4-<n sh,--J x a. __. -

1 QUAD CITIES UNITS 1 & 2 DPR-29 & DPR-30 4.0 EMByMIANCE REQQ1BEMENTS BASEE specifications 4.0.A through 4.0.E establish the general requirononts applicable to Surveillance Roquirements. Thoso requirements are based on the survol11anco Requirements stated in th- Code of Federal Regulations, 10 CPR 50.36(c) (3) :

"Surveillanco requirements are requirements relating to test, calibration, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be mot."

4.0 A Specification 4.0. A establishes the requirement that surveillances must be performed during the reactor OPERATIONAL MODES or other conditions for which the requirements of the LCO apply unless otherwise stated in an individual Surveillance Requirement.

The purpose of this epocification is to ensure that surveillances are performed to verify the operational status of systems and components and that paramotors are within specified limits to ensure safe operation of & facility when the plant is in a reactor OPERATIONAL NODE or other specified condition for which the individual LCOs are applicable. Surveillance Rnquirements do not havo to be performed when the facility is in a reactor OPERATIONAL MODE for which the requirements of th" associated LCO do not apply unless otherwiso specified.

Surveillanco Requirements do not have to bo l performed on inoperable equipment because the ACTION l requirements define the remedial measures that I

apply. Ilowever, the Surveillance Requirements have to be mot to demonstrate that inoperable equipment has boon restored to OPERABLE status.

4.0.B Specification 4.0.B establiches the limit for which i the specified timo interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conductinst the surveillanco; e.g., transient conditions or other ongoing surveillance or maintenanco activities. It also l

provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at B 3.0/4.0-6

QUAD CITIES UNITS 1 & 2 DPR-20 & DPR-30 each refueling outage und are specified with an 18 month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyonc that specified for surveillances that are not performed during refueling outages. The limitat.4on of Specification 4.0.B is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

4.0.C Specification 4.0.C establishes that the failure to '

satisfy a Surveil) .'ce Requirement within the maximum allowed surveillance interval, defined by the provisions of Specification 4 . 0. B ,- is a condition that constitutes - a failure to meet the OPERABILITY recuirements for a LCO. Under the provisions of 'this specification, systems and components are assumed to be OPERABLE when Surveirlc.nce Requirements have been satisfactorily performed within the specified time interval.

However, nothing in this provision is to be construed as implying that systems or components are OPERABLE when they are found -or known to be inoperable although still meeting the Surveillance Requirements. This specification also clarifies th0t the ACTION requirements are applicable when Surveillance Requirements have not been completed within the maximum allowed surveillanca interval.

The time limits of the ACTION requircments apply from the point in time it is identified that a

. surveillance has not been performed and not from the time that the allowed surveillance interval was exceeded. Cong etion of the Surveillance Requirement within the allowable outage time limits of the ACTION requirements restores compliance with the requirements of Specification 4.0.C. However, this does not negate the fact that the failure to have performed the surveillance within the allowed surveillance interval, defined by the provisions of Specification 4. 0.B, constitutes a failure to meet the OPERABILITY requirements for a LCO. The failure to perform a surveillance within the provisions of Specification 4.0.B is a violation of a Technical B 3.0/4.0-7

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QUAD CITIES UNITS 1 &2 DPR-29 & DPR-30 Specification requiremant and is, therefore, a reportable event under the requirements of 10 CFR 50.73 (a) (2) (i) (B) because it is a condition

'rohibited by the plant's Technical Specifications.

If the allowable outage time limits of the ACTION requirements are less than or equal to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or a shutdown is required to comply with ACTION requirements (e.g., in Specification 3.0.C), a 24-hour allowance is provided to permit a delay in implementing the ACTION requirements. This provides an adequate time limit to complete Surveillance Requirements that have not been performed. The purpose of this allowance is to permit the completion of a surveillance before a shutdown would

-be required to :emply with ACTION requirements or before other remedial measures would be required that may preclude the completion of a surveillance.

The basis for this allowance includes consideration for plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and the safety significance of the delay in completing the required surveillance. If a surveillance is not completed within the 24-hour allowance, the time limits of the ACTION requirements are applicable at that time.

When a surveillance is performe1 within the 24-hour allowance and the Surveillance Requirements are not met, the time limits of the ACTION requirements are applicable at the time that the survaillance is terminated.

4.0.D Specification 4.0.D establishes the requirement that all -applicable surveillances must be met before entry into an OPERATIONAL MODE or other condition of operation specified in the Applicability statement.

The purpose of this specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into an OPERATIONAL MODE or other specified condition for which these' systems and components ensure. safe operation of the facility. This provision applies to changes in CPEPATIONAL MODES or other specified conditions associated with plant shutdown as well as startup.

Under the provisions of this specification, the applicable Surveillance Requirements must be performed within the specified surveillance interval B 'a.0/4.0-8 1

QUAD CITIES UNITS 1 & 2 DPR-29 & DPR-30 to assure that the LIMITING CONDITIOi.S FOR OPERATION are met during initial plant start ( or fr11owing a plant outage.

When a shutdown is required to comply with ACTION statements, the provisions of Specification 4.0.D do not apply because this would delay placing the facility in a lower OPERATIONAL MODE.

4.0.E Specification 4.0.E establishes the requirement that inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Cr - Class 1, 2, and 3 pumps and valves shall be per* ad in accordance with a periodically updated vt .. n of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CFR 50.55a.

These requirements apply except when relief has been provided in writing by the Commission.

This specification includes a clarification of the frequencies for performing the inservice inspection and testing activities required by Section XI of the i ASME Boiler and Pressure Vessel Code and applicable l Addenda. This clarification is provided to ensure consistency in surv7111ance intervals throughout the Technical Specifications and to remove any ambiguities relative to the frequencies for performing the required inservice inspection and testing activities.

Under the terms of this specification, the more restrictive requirements of the Technical Specifications take precedence over the ASME Boiler and Pressure Vessel Code and applicable Addenda.

The requirements of Specification 4.0.D to perform surveillance requirements before entry into an OPERATIONAL MODE or other specified condition takes precedence over the ASME Boiler and Pressure Vessel Code provision t. it allows pumps and valves to be tested up to one week after return to normal operation. The Technical Specification definition of OPERABLE does not allow a grace period before a component, which is not capable of performing its specified function, is declared inoperable and takes precedence over the ASME Bciler and Pressure Vessel Code provision that allowc a valve to be incapable of performing its specified function for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before being declared inoperable.

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EXISTING TECH SPEC 1

TS 3.0/4.0

' A P P LICABILIT Y'

T QUAD-CITIES OPR-29 3.0/4.0 Limiting Conditions for Operation (General)

Applicability:

Applies to systems, subsystems, trains, components, or devices required to be operable.

Objective:

To assure that no set of equipment outages would be allowed to persist that would result in the facility being in an unprotected condition.

LIMITING CONDITION FOR OPERATION A. Limiting Condition for Operation cannot be satisfie use-trf circumstances in ex addressed in th n, the unit shall be placed in at least HOT SHU '

nd in COLD SHUT 00WN within the followi ess corrective measures are comp -thq ttrr mi ing Conditions for Operation.

B. When a system, subsystem, train, component, or device is determined toy inoperable wkly b:ccuse-4h emergency power source h inoper2% or stdely i

,no era becau:c ft:' normal power source,i: incperab h , M may be considered OPERABLE for the purpose of satisf g ,qs $ln, CfrJ$fffgr$ /Ef. Off/(ffl//,provided:

ying the requirements o itsapplicableLfsffffff 3 #$(o 8

[ .(Iv9/tscorrespondingnormaloremergencypowersourceis0PERABLE,and (2/)/11 of its redundant systerr(s), subsystert(s), train (s), component (s), and devict's) in the other di',ision are OPERABLE, or likewise satisfy the requirements of this specification.

Unless both conditions (1[and(2[are satisfied, the unit shall be placed in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in at least COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

f. 3 Specification)( 0.0. A and 3.0.S are not applicable in ///MM/g or 8// /dRM//.

3.0/4.0-1 Amendment No. 114 l

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00AD-CITIES OPR-29 3.0/4.0 BASE 5 3.O.A Thi; :pecf Heation delineates the action to be taken for circumstances not direct 1y provided' for in the- Limiting conaii.io" '^ r 0;;rdi - aiements and whose occurrence

_would vidste Uw intent of the specification.

'3. 0.)f E J.C. 6 Thit/pecification4 delineates what additional conditions must be satisfied to permit operation to c ntinue, consistent with the L///(fgC//////(p /// 0//fiffS statemenu ~

for power-sou s, when a normal or emergency power source is not OPERABLE. dt -

specifically p.shibits operation when one division is inoperable because_its' normal or emergency power source is . inoperable and a system, subsystem, _ train, component. or device in another division is inoperable for another reason / Power sources are defined] .

(a's~ AC Auxiliary Electrical Systems as notea in section 3.9JA.1, 3.". A.2, =c 3.S. ". 3.

.The provisions of this _ specification permit the l/Mlf// C(pgf(f// /d/ 0///////ff subs devices to be- consistent with the LAf/dfi Chhlstatements : associated with individu associated electrical power source. It allows operati n to be governed by the time limits of the ///f(/ statements associated with the ffA ff/ 0///////ff for the normal or emergency power source, not the individual statements for each

' system, subsystem, train, component, or device that is determined to be inoperable solely because of the inoperability of its normal-or emergency power source.

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l 3.0/4.0-2 Amendment No. 114

1 SIGNIFICANT HAZARDS CONSIDERATIONS AND ENVIRONMENTAL ASSESSMENT EVALUATION PROPOSED TS 3.0/4.0 APPLICABILITY'

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EVALUATION EQB plGJlET_QAUT }IAZARDS CONSIDERATION PROPOSED SPECIFICATION 3.0/4.0 APPLICABILITY The proposed changes provided in this amendment request are made in order to provide General Provisions for Limiting Conditions for Operation and Surveillance Requirements consistent with later BWR plants and Quad Cities present and past operating practices.

These changes have been reviewed by Commonwealth Edison and we believe that they do not present a Significant Hazards Consideration. The basis for our determination is documented as follows:

BASIS EOB HQ EIGNIFICANT HAZARDS CONSIDERATION Commenwealth Edison has evaluated this proposed amendment and determined that it involves no significant hazards consideration. In accordance with the criteria of 10 CFR 50.92(c) a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility, in accordance with the proposed amendment, would not:

1) Involve.a significant increase in the probability or consequences of an accident previously evaluated because:

Many of the changes in this proposed amendment are more restrictive than present Technical Specification requirements.

These more restrictive requirements will help to ensure that the intent of plant operating philosophy embodied in more recent BWR plants is included in the Quad Cities Technical Specifications. The inclusion of these requirements will also provide clarification to the plant operating staff and help to prevent misinterpretations. Most of the changes are modeled after those proposed in Generic Letter 87/09 instead of the present BWR/4 STS since the Generic Letter was prepared in part to correct inconsistencies in the present wording of the general Sections 3.0 and 4.0 of the STS. Since this amendment request retains' the provisions of present LCO 3.0. A and 3.0.B, adds more restrictive provisions, and provides administrative changes to correct inconsistencies found in the STS, there is no significant increase in the probability or consequences of an accident previously evaluated.

This proposed amendment request -inc.tudes the provisions of Generic Letter 89/14 which deletes the 3.25 limit from This deletion has been reviewed by NRC Specification 4.0.B.

Staff and found to result in a greater benefit to safety. The Staf f concluded that the provisions of the letter will remove an unnecessary restriction of extending surveillance requirements and will result in a benefit to safety when plant conditions are not conducive to the safe conduct of

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i surveillance requirements. The Staff further concluded that removal of the 3.26 limit will provide greater flexibility in the use of the provision for extending surveillance intervals, reduce the administrative burden associated with its use, and have a positive effect on safety. Commonwealth Edison agrees with the Staff conclusions and also concludes that the provisions of Generic Letter 89/14 should be implemented at Quad Cities Units 1 and 2. Therefore, the inclusion of Generic Letter 89/14 requirements does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Create the possibility of a new or different kind of accident from any previously evaluated because:

The proposed changes will place in Sections 3.0 and 4.0 all the general provisions governing use of LCOs and Surveillance Requirements. The changes embody present operating philosophy contained in the individual speelfications and add Generic Letters 87/09 and 89/14 provisions which have been evaluated by the NRC and found acceptable for inclusion in the Technical Specifications. The proposed changes do not allow any new modes of plant operation and considering the administrative nature of the Generic Letter 87/09 changes, there is no possibility of a new or different kind of accident.

3) Involve a significant reduction in the margin of safety because:

The more restrictive provisions proposed to be added by this amendment will increase the margin of safety by clearly defining to the plant operating personnel the governing LCO and Surveillance Requirement provisions. These new provisions will help to prevent misinterpretation where no requirements are presently stated. Since more restrictive requirements are proposed, this amendment does not involve a significant reduction in the margin of safety.

The provisions of Generic Letters 87/09 and 89/14 have been evaluated by NRC Staff and found acceptable for plant use. In addition, Commonwealth Edison has evaluated-these provisions for inclusion at Quad Cities Units 1 and 2 and has concluded that the margin of safety is preserved or improved by using the proposed changes.

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ENVIRONMENTAL ASE18SILRNiT EYALUATION PROPOSED SPECIFICATION SECTION 3.0/4.0 APPLICABILITY Commonwealth Edison has evaluated the proposed amendment in accordance with the requir:5ents of 10 CFR 51.21 and has determined that the amendment meets the requirements for categorical exclusion as specified by 10 CFR 51.22(c) (9) .

Commonwealth Edison has determined that the amendment involves no significant hazards consideration, there are no significant. change in the types or significant increase in the amounts of any effluent that may be released offsite, and there is no significant-increase in individual or cumulative occupational radiation exposure.

The proposed amendment does not modify the existing '

facility and does not involve any new operation of the plant.

As such, the proposed amendment does not involve any change in the type or significant increases in effluents, or increase individual-or cumulative-occupational radiation exposure. The proposed amendment to Section 3.0,

" Applicability" retains the intent of existing Specification 3.0. A and 3.0.B and adds requirements which are currently not delineated in the specification but are implemented as standard operating procedure at newer boiling water reactor facilities. The addition of these new provisions provides better direction to operators under certain plant conditions.

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QC-1/ QC-2 DIFFERENCES TS 3.0/4,0

' APPLICABILITY'

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COMPARISON OF UNIT 1 AND UNIT 2 TECHNICAL SPECIFICATIONS FOR THE IDENTIFICATION OF TECHNICAL DIFFERENCES SECTION 3.0/4.0 APPLICABILITY

Commonwealth Edison has conducted a comparison review of the Unit 1 and Unit 2 Technical Specifications to identify-any technical differences in support of combining the Technical Specifications'into one document. The intent of-the review was-not to identify any differences in presentation style (e.g. table formats, use of capital letters, etc.) or punctuation but rather to identify areas

-which the Technical Specifications are technically different.

LThe review of Section 3.0/4.0, " Applicability" did not identify eny technical-differences.

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