ML20079F987

Application for Amends to Licenses NPF-29 & DPR-30,changing TS to Reflect Util Efforts to Upgrade Existing TS 3.8/4.8, Radioactive Effluents & 3.10/4.10, Refueling

ML20079F987
Person / Time
Site:	Quad Cities
Issue date:	09/30/1991
From:	Stols R COMMONWEALTH EDISON CO.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20079F990	List: ML20079F987 ML20079F992
References
NUDOCS 9110080352
Download: ML20079F987 (18)

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'v September 30,1991 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk

Subject:

Quad Cities Nuclear Power Station Units 1 and 2 Appilcation for Amendment to Facility Oaerating Licenses DPR 29 and DPR 30, Append x A, Technical Specifications Technical Specification Upgrade Program NRC_DocheWosm50-25Aand.50 265 i

Dr. Murley:

l In 1990, Quad Cities Station initiated a formal program to enhance the Station's performance in various aspects of plant operation. The Performance Enhancement Program (PEP) was developed by assessing existing improvement

, alans, Identifying potential weaknesses and prioritizing improvement actions.

l 1ecessary improvements to the Technical Specifications were identified as one of the Station top priority issues. Details of the goal and methodology for the Technical Specification Upgrade Program are provided in the Executive Summary section of the proposed amenc ment. The Program has been previously discussed with members of the NRR staff.

Pursuant to 10 CFR 50.90, Commonwealth Edison proposes to amend Appendix A Technical Specifications to Facility Operating Licenses DPR-29 and i

DPR-30. The proposed amendment reflects Commonwealth Edison's efforts to l upgrade the following existing Technical Specification Sections: 3.8/4.8, " Radioactive Effluents",3.10/4,10," Refueling". An overall description of the proposed amendment is also included in the Executive Summary.

The proposed amendment request for each Technical Specification section is provided as follows:

1. An Executive Summary of the Technical Specification Upgrade Program and the proposed amendment;

2. A summary of the changes;

3. A detailed description of the changes; Ecc 4. The proposed Technical Specification pages with the requested changes; ocm i SS' 5. The existing Technical Specification pages for DPR-29, are marked-up to 38 40 reflect the appropriate changes to the existing bases sections.

Nx 6. Commonwealth Edison's evaluation pursuant to 10 CFR 50.92(c) and l $ 10 CFR 51.21; and,

7. The technical differences between the existing Unit 1 and Unit 2 Technical Scc Specifications.

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O O Dr. Thomas E. Murley September 30,1991 The 3roposed amendment has been reviewed and approved by Commonwealt 1 Edison's on site and off site review in accordance with Company procedures.

The Technical Specification Upgrade Program proposes changes to each section of the existing Tecl1nical Specifications. As such, Commonwealth Edison rec uests that the proposed amendments be approved and issued as one document ratier than as individual sections. Commonwealth Edison respectfully requests the NRC's approval of the upgraded Technical Specifications by July 1,1992.

To the best of my knowledge and belief, the statements contained are true md correct, in some respects, these statements are not based on my personal Knowledge but obtained information furnished by other Commonwealth Edison employees and consultants. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

Commonwealth Edison is notifying the State of Illinois of this application for amendment by transmitting a copy of this letter and its attachments to the designated State Official.

Please direct any questions concerning this proposed amendment to J. Schrage at 708/515 7283.

Very truly yours, Rita Stols Nuclear Licensing Administrator Enclosure (A): 3.8/4.8, " Radioactive Effluents" (B): 3.10/4.10, " Refueling" ,

cc: A.B. Davis, Regional Administrator L.N. Olshan, Project Manager T.E. Taylor, Senior Resident inspector Illinois Department of Nuclear Safety State of hh, County of ned bbfore me on this& day Sig$h/e_,1991 of, 7

Notary Public

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QUAD CITIES NUCLEAR POWER STATION TECHNICAL SPECIFICATION UPGRADE PROGRAM a

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PROPOSED AMENDMENT SECTION 3.8/4.8 " Radioactive Effluents"

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, " EXECUTIVE

SUMMARY

Proposed . Changes to TS 3.8/4,8-RADIOACTIVE EFFLUENTS * -

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EXECUTIVE MQiABX QUAD CITIES TECHNICAL BPECIFICATICN 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 requirements which are no longer consistent with current industry practices.

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 appropriate.

The comparison study revealed a mix of recommended upgrades which included the relaxation of certain existing Technical Specification requirements, the addition of surveillances, the removal of allowances which would no longer be allowed under new plant licensing, and better definition of appropriate action requirements in the event a Liraiting 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 decument. To accomplish the combination of the Units' Technical Spocifications, a comparison of the Unit 1 and 2 Technical Specifications was performed to identify any technical differences. The technical differences are identified in the proposed amendment package for each section.

The Technical Specification Upgrade Program was identified as a Station top priority during the development of Quad Cities Station's Performance Enhancement Program (PEP). The Technical Specification Upgrade 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.-

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O e EXECITTIVE

SUMMARY

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Proposed Technical Specification Section 3.8/4.8, " Radioactive Effluents" roposed change deletes the present objective statement and The$desApplicabilitystatementswithineachspecification prov similar to the STS. The proposed Applicability statements include the Reactor Modes and other conditions for which the LCOs must be satisfied. An STS type of format is proposed while retaining the present two column layout <

In accordance with the guidelines of Generic Letter 89-01, Radiological Effluent Technical Specifier.tions (RETS) programmatic requirements are. relocated to the Administrative Controls section of the technical specifications and the procedural details are relocated to the ODCM (Offsite Dose Calculation Manual) or to the PCP (Process Control Program).

To conform to the regulatory requirements of 10 CFR 20.106, 40 CFR Patt 190, 10 CFR 50.36a, and Appendix I to 10 CFR 50, new programmatic controls for radioactive effluants and radiological environmental monitoring are relocated to Section 6.0 of the technical tpecifications.

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SUMMARY

OF CHANGES Proposed --TS 3.8/4.8 b

' RADIOACTIVE EFFLUENTS'

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o o BUMMARY QI CHANGER Proposed Specification 3.8/4.8 Radioactive Effluents This amendment package is one in a series of proposals that will provide improvements to the present Quad Cities Technical Specifications. The summary of changes includes a general section to describe generic changes that are applicable to more than one section of the technical specifications and a section which provides the changes that are page by page specific.

GENERIC CHANGES Item 1 The present Applicability statements at the beginning of Technical Specification Section 3.8/4.8 are being deleted. The Applicability statement is being included after the LCO statement in each individual specification.

Item 2 Each specification is rearranged to follow an STS type of format while retaining the present two column layout. Each specification will contain an LCO, Applicability, Action and Surveillance Requirement sec'lon,c as applicable.

Item 3 The Bases for each technical specification section is relocated to the end of the section.

SPECIFIC CHANGES Item 1 Paces 3.8/4.8-1 throuch 3.8/4.8-6. Specifications 2 8.A.1/4.8.A.1 through 3.8.A.3/4.8.A.3. DPR-22 Gaseous Effluent Specifications 3.8.A.1/4.8.A.1, 3.8.A.2/4.8.A.2,

'3.8.A.3/4.8.A.3, and 3.8.A.4/4.8.A.4 are deleted and relocated to the ODCM in accordance with Generic Letter 89/01.

Item 2 Paces 3.8/4.8-7 and 3.8/4.8-8. Specifications 3.8.A.5/4.8.A.5 add 3.8.A.6. DPR-29

a. Presant Explosive Gas Mixture Specifications 3.8.A.5/4.8.A,5, 3.8.A.6, and Specification 3.8.G are rewritten as proposed Specification 3.8.A/4.8.A.

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c. Proposed LCO and Actions are taken from present requirements,

c. Proposed Applicability of Operational Modes 1 and 2, whenever reactor vessel pressure is greater than 900 psig, implements the intent of present provisions,

d. Present Surveillance Requirement 4.8.A.5 is changed from an eight hour frequency to at least once per shift.

Item 3 Page 3.8/4.8-8, Specification 3.8.A.7/4.8-A.7, DPR-29

a. Present Main Condenser Specifications 3.8.A.7/4.8.A.7 are rewritten as proposed Specifications 3.8.D/4.8.B.

b. Proposed LCO and Surveillance Requirements are taken from present provisions.

c. Proposed Actions are based on present provisions to take the plant to Hot Standby if release ratos are not restored,

d. Proposed Applicability is whenever the main condenser air ejector is in operation and is based on later operating plants' provisions.

Item 4 e 3.8/4.8-9 through 3 .,8 / 4 . 8 - 13 , Specification 3.8.B/4.8.D, Present Liquid Effluents Technical Specifications 3.8.B/4.8.B are deleted and relocated to the ODCM in accordance with the guidelines of Generic Letter 89/01.

Item 5 Page 3.8/4.8-13, Specification 3.8.C/4.8.C, DPR-29

a. Present Mechanical Vacuum Pump Specification 3.8.C/4.8.C is rewritten as proposed Specification 3.8.C/4.8.C using present requirements or intent of present requirements,

b. Proposed LCO and Surveillance Requirements are based on present provisions.

c. Proposed Applicability of Operational Modes 1, 2, and 3, when the main steamline isolation valves are open, implements the intent of present provisions. Present provisions require the capability to isolate the mechanical vacuum pump on a signal of main steamline tunnel high radiation when the main steamline isolation valves are open.

d. Present Action provisions require the mechanical vacuum pump i

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to be isolated and secured if the LCO is not met. Proposed Action 3.8.C.1 implements the present Action provisions by allowing 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to isolate and secure the mechanical vacuun pump. Proposed Action 3.8.C.2 provides an exception to the provisions of Specification 3.0.C in accordance with present Specification 3.8.G.

Item 6 e 3.8/4.8-13 through 3.8/4.8-16, Specification 3.8.D/4.8.D, Present Environmental Monitoring Program Specifications 3.8.D/4.8.D are deleted and relocated to the ODCM in accordance with the provisions of Generic Letter 89/01.

Item 7 Page 3.8/4.8-17, Specification 3.8.E/4.8.E t DPR-29 Present Solid Radioactive Waste Specifications 3.8.E/4.8.E are deleted and relocated to the PCP in accordance with the provisions of Generic Letter 89/02.

Item 8 Pages 3.8/4.8-17 and 3.8/4.8-18, Specification 3.8.F/4.8.F, DPR-29

a. Present Miscellaneous Radioactive Materials Sources Specifications 3.8.F/4.8.F are retitled as " Sealed Source Contamination" and rewritten as Specification 3.8.D/4.8.D.

b. Proposed LCO, Applicability, Actions and Surveillance Requirements are taken from present provisions.

Item 9 e 3.8/4.8-18 through 3.8/4.8-21, Specification 3.8.H/4.8.H,

a. Present Control Room Emergency Filtration Specifications 3.8.H/4.8.H are rewritten as proposed Specification 3.8.E/4.8.E ucing present provisions or intent of present provisions.

b. Proposed LCO 3.8.E implements present provisions,

c. Proposed Applicability implements present provisions that require Control Room Emergency Filtration System Operability when Secondary Containment Integrity is required.

d. Proposed Actions implement the intent of present provisions by allowing continued reactor operation and fuel handling for 14 days and then within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, the plant must be

placed in a cendition where Secondary containment Integrity is not required. Proposed Action 3.8.E.1 requires that with the Control Room Emergency Filtration System inoperable, 14 days is allowed to restore the system to operable status or if the reactor is in operational Modes 1, 2, or 3, the reactor must be 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 in at least Cold Shutdown within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. With the control Room Emergency Filtration System inoperable, proposed Action 3.8.E.2 implements the STS guidelines by requiring suspension of: irradiated fuel or fuel cask handling in the reactor building; CORE ALTERATIONS; or operations with a potential for draining the reactor vessel. 4

e. Proposed Surveillance Requirements in 4.8.E are written by using present 3.8.H.1 and combining the present provisions of Specifications 3.8.H.2, 3.8.H.3, 4.8.H.2 and 4.8.H.3.

As with the proposed Standby Gas Treatment System Specifications, surveillence frequencies are modified to reflect a dependence on accumulated system operating time.

Item 10 Pa es 3.8/4.8-22 through 3.8/4.8-26, Bases for Section 3.8/4.8, UP - 9 The Bases for Section 3.8/4.8 are rewritten in order to-implement the changes proposed to the Specifications in Section 3.8/4.8.

' Item 11 Pages 3.8/4.8-27 through 3.8/4.8-38, Tables 4.8-1, 4.8-2, 4.8-3, 4.8-4, 4.8-5 and 4.8-6, DPR-29 Present Tables 4.8-1, 4.8-2, 4.8-3, 4.8-4, 4.8-5 and 4.8-6 are

-deleted and relocated to the ODCM in accordance with the provisions of Generic Letter 89/01.

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-Figure 4.8-1, DPR-29 Present Figure 4.8-1, Unrestricted Area Boundary, is relocated to Section 5.0, Design Features.

DESCRIPTION OF CHANGES Proposed TS 3.8/4.8

' RADIOACTIVE EFFLUENTS'

e a DEECRIPTION QZ PROPOSED MiRNDMENT REQHRET Proposed Specification 3.8/4.8 Radioactive Effluents The changes proposed in this amendment request are made to 1) impreve the understanding and usability of the present technical specifications, 2) incorporate technical improvements, and 3) include some provisions from later operating BWR plants.

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.

GENERIC CHANGES Item 1 Present Quad Cities Technical Specification Section 3.8/4.8 contains Applicability statements at the beginning of the ee tion. These statements are generic in nature and do not provide any useful information to the user of the technical specifications. The proposed change will delete the present Applicability statement and provide Applicability statements within each specification similar to the STS. The proposed Applicability statement to be included in each specification will include the Reactor Operational Modes or other conditions for which the LCO must be satisfied.

Item 1 The changes proposed in this item will provide an STS type of format while retaining the present two column layout. The present format does not provide a separation of LCO, Applicability, and Action requirements that are easily understood and identified.

The two column layout has been utilized at Quad Cities since initial licensing of the plant and is preferred by the plant over the. single column STS layout.

Item 1 This item provides the relocation of the baces of the technical cpecifications from the present location of immediately following the LCO material to the end cf the section. For sections with tables or figures, the tables and figures will now be located after the LCos and before the bases. This change recognizes that the bases provide reference material which is of secondary importance to the other material in the technical specifications.

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O 6 SPECIFIC CHANGES 119E 1 The proposed changes to the Technical Specifications in Item 1 involve deleting present Gaseous Effluent Specifications 3.8.A.1/4.8.A.1, 3.8.A.2/4.8.A.2, 3.8.A.3/4.8.A.3, and 3.8.A.4/4.8.A.4 and relocating these requirements to the ODCM in accordance with the guidelines of Generic Letter 89/01.

The NRC issued Generic Letter 89/01 after reviewing the Commission's Interim Policy Statement on Technical Specification Improvements in relation to the contents of the Radiological Effluent Technical Specifications (RETS). The NRC Staff then determined that programmatic controls can be implemented in the Administrative Controls section of the Technical Specifications to satisfy existing regulatory requirements for RETS. At the same time, the procedural details of the current TS on radioactive effluents and radiological environmental monitoring can be relocated to the Offsite Dose Calculation Manual (ODCM).

Likewise, the procedural details of the current TS on solid radioactive wastes can be relocated to the Process Control Program (PCP). These changes simplify the RETS, meet the regulatory requirements for radioactive effluents and radiological environmental monitoring, and are provided as a line-item improvement of the TS, consistent with the goals of the Policy Statement. These proposed changes in Section 3.8/4.8 are a part of the GL 89/01 changes which also affect Sections 1.0, 3.2/4.2 and 6.0. The proposed changes in the other TS sections are discussed with the proposed changes to each specific section.

1123 2 Proposed Explosive Gas Mixture Specification 3.8.A/4.8.A is written from the present provisions of Specitications 3.8.A.5/4.8.A.5 and 3.8.G. Proposed LCO 3.8.A and Applicability are taken from present provisions of 3.8.A.S.a. The proposed LCO requires the concentration of hydrogen in the Off-Gas hold up system, downstream of the recombiner to be limited by having a recombiner operable within the allowable band of the base-line plot of recombiner outlet temperature vs. reactor power. The proposed Applicability of Operational Modes 1 and 2, whenever Reactor Vessel Pressure is greater than 900 psig implements present specification intent of whenever the reactor is operating at a pressure greater than 900 psig. Proposed Action 3.8.A.1 implements present 3.8.A.5.b provisions and allows the recombiner ,

to be inoperable for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Proposed Action 3.8.A.2 for the Explosive Gas Mixture Specification implements present provisions of 3.8.A.6 and reguires Special Reports to be submitted to the NRC with recombiners inoperable for more than 7 days in a calendar quarter while operating above 30% Rated Thermal Power. In accordance with present provisions of 3.8.G, the provisions of 3.0.C for plant shutdown are not applicable for this specification. The intent of present Surveillance Requirement

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4.8.A.5 is implemented as proposed SR 4.8.A and requires a verification at least once per shift that the LCO limits are being met. The at least once per shift test frequency replaces the present 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> test frequency and implements the intent of STS testing frequencies proposed in Table 1-1.

Item 1 Proposed Main Condenser Specification 3.8.B/4.8.B is written from present Specification 3.8.A.7/4.8.A.7. The proposed LCO of requiring the release rate of the sum of the activities from the noble gases measured at the main condenser air ejector to be limited to less than or equal to 100 microcuries/sec per MWt (after 30 minute delay), implements present provisions of 3.8.A.7.

Proposed Applicability of whenever the main condenser air ejector is in operation replaces present provisions of at all times.

Since releases can only be obtained when the main condenser air ejectors are in operation, the proposed Applicability which is taken from later operating plants' provisions, is acceptable for use at Quad Cities. The proposed Action, if the LCO limit is exceeded, allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the release rate to within its limit or the plant must be in at least Hot Standby within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The proposed Action implements present provisions in 3.8.A.7 to go to at least Hot Standby. Proposed Surveillance Requirements in 4.8.B are taken from present provisions. Proposed ,

SR 4.8.B.1 implements a part of present 4.8.A.7 and requires the radioactivity release rate of noble gases at (near) the outlet of the main condenser air ejector to be continuously monitored in accordance-with the provisions of the ODCM. The present SR references Specification 3.2.H instead of the ODCM; however, present 3.2.H is being moved to the ODCM in accordance with the provisions of Generic Letter 89/01. Proposed SR 4.8.B.2 implements parts of present 4.8.A.7 and requires samples to be taken and analysed at least once per 31 days and within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following an increase of greater that 50% in the nominal steady-state fission gas release from the primary coolant.

Item A Present Liquid Effluent Specifications 3.8.B/4.8.B are deleted and relocated to the ODCM as part of the changes required in order to

. implement Generic Letter 89/01. See Item 1 above for a discussion of GL 89/01 implementation.

Item 5 Proposed Mechanical Vacuum Pump Specification 3.8.C/4.8.C is written using the provisions of present Specification 3.8.C/4.8.C.

The proposed LCO implements present 3.8.C.1 provisions that require the mechanical vacuum pump to be capable of being isolated and secured on a signal of main steamline tunnel high radiation.

Present Applicability of whenever main steamline isolation valves are open is implemented in proposed Specification 3.8.C with a qualification that the plant also be in Operational Modes 1, 2, L.

• o or 3. Proposed Action 3.8.C.1 implements present 3.8.C.1 requirements to isolate and secure the mechanical vacuum pump if the main steamline high radiation isolation is inoperable.

Proposed Action 3.8.C.1 allows a reasonable time frame of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for the mechanical vacuum pump to be isolated and secured.

Proposed Action 3.8.C.2 implements the provisjons of present 3.8.G by stating that the provisions of Specification 3.0.C are not applicable. Present Surveillance requjrement 4.8.C is retained as proposed SR 4.8.C and requires that at least once per operating cycle the automatic securing and isolation of the mechanical vacuum pump be verified.

Item i Present Environmental Monitoring Program Specifications 3.8.D/4.8.D are deleted and relocated to the CDCM in accordance with the implementation guidelines contained in Generic Letter 89/01. See Item 1 above for a discussion of GL 89/01 implementation.

Item 1 Present Solid Radioactive Waste Specifications 3.8 E/4.8.E are deleted and relocated to the PCP in accordance with the implementation guidelines in Generic Letter 89/01. See Item 1 above for a discussion of GL 89/01 implementation.

Item a Present provisions of Specification 3.8.F/4.8.F, Miscellaneous Radioactive Materials Sources, are used to write proposed Specification 3.8.D/4.8.D, Scaled Source Contamination. Proposed LCO 3.8.D is taken from present 3.8.F and requires each sealed source containing radioactive material either in excess of 100 microcuries of beta and/or gamma emitting material or 5 microcuries of alpha emitting material to be free of 2 0.005 microcuries of removable contamination. Proposed Applicability of at all times implements present intent and follows later operating plants' provisions. The proposed Applicability is necessary since sealed sources may be in use during all plant operating conditions. Proposed Action 3.8.D.1 implements present provisions in 3.8.F.1 and requirec that a sealed source having removable contamination in excess of the limit be removed from use and either decontaminated and repaired or disposed of in accordance with Commission Regulations. Proposed Action 3.8.D.2 is taken from later operating plantu' provisions and allows an exception to the provisions of Specification 3.0.C. Changes in plant operating conditions required by Specification 3.0.C are needed when conditions exist outside of the specifications that warrant an immediate plant shutdown. Violations of Sealed Source Contamination limits do not warrant an immediate plant shutdown and the provisions of proposed Action 3.8.D.1 are sufficient to ensure safe handling and possible disposal of these sources.

Proposed Surveillance Requirements 4.8.D.1, 4.8.D.2 and 4.8.D.3

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implements testing and reporting requirements for Scaled Sources contained in present SRs 4.8.F.1 and 4.8.F.2. Proposed SR 4.8.D.4 is taken from present 3.8.F and requires a complete inventory of radioactive materials in the licensee's possession to be maintained current.

Item 2 Proposed Control Room Emergency Filtration System Specification 3.8.E/4.8.E is based on provisions of present Specification 3.8.H Proposed LCO 3.8.E is taken from present 3.8.H.1 and requir/4.8.H.es the Control Room Emergency Filtration System including at least ene booster fan to be operable. Proposed Applicability impler its the intent of present 3.8.H.1 of when secondary contai. lent integrity is required by referencing the secondary containment Applicability provisions of Specification 3.7.I. An exception to the Applicability implements present 3.8.H.1.b and states that the specification does not apply during performance of

-post-maintenance testing, or during removal of the charcoal test canister. Proposed Action 3.8.E.1 implements the intent of present 3.8.H.1.a by allowing 14 days to restore the inoperable system to OFERABLE status if in Operational Modes 1, 2, or 3, or else, requiring the plant to be placed in at least Hot Shutdown within the next 32 houts and in at least Cold Shutdown within the following 24 nours. With the Control Room Emergency Filtration System inoperable, proposed Action 3.8.E.2 implements the STS guidelines by requiring suspension of: irradiat e.* fuel or fuel cask nandling in the reactor building; CORE ALTERATIONS; or operations with a potential for draining the reactor vessel.

In accordance with later operating plants' provisions an exception is added such that the provisions of Specif1 cation 3.0.C are not applicable for fuel handling operations when all fuel is romoved from the reactor and the plant is not in any Operational Mode. Fuel Handling operations do not affect plant Operational Modes and as such, inoperability of the control room emergency filtration system during fuel handling operations should not require changes in plant operational Modes. If inoperability of toe control room emergency filtration system occurs during Operational Modes 4 or 5, then the provisions of Specification 3.0.C do not apply as stated in proposed Specification 3.0.C.

Proposed Surveillance Requirement 4.8.E.1 implements present 4.8sH.1 provisions for monthly testing of the control room emergency filtration system for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the heaters operable. Proposed SRs 4.8.E.2, 4.8.E.3, 4.8.E.4 and 4.8.E.5 implement the Periodic Performance and Postmaintenance Testing requirements of present 3.8.H.2, 4.8.H.2, 3.8.H.3 and 4.8.H.3. As with the proposed Standby Gas Treatment System Specifications, the frequency of proposed SR 4.8.E.2 is modified to include a dependence on accumulated system operating time of 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br />.

Item la The proposed changes to the Bases for Section 3.8/4.3 are necessary in order to implement the changes described above to the l

s a individual Specifications.

Itam 11 Present Tables 4.8-1, 4.8-2, 4.8-3, 4.8-4, 4.8-5 and 4.8-6 are deleted and relocated to the ODCM in order to implement the guidelines of Generic Letter 89/01. See Item 1 above for a discussion of the implementation of GL 89/01.

ItME 12 Present Figure 4.8-1, Unrestricted Area Boundary, is proposed to be relocated to Section 5.0, Design Features. This change follc*ie

• STS guidelines and allows a section to be added to address this figure.

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