ML20079G092

Application for Amends to Licenses DPR-29 & DPR-30,changing TS to Reflect Effort to Upgrade Existing TS Sections: 3.2/4.2, Protective Instrumentation & 3.9/4.9, Auxiliary Electrical Sys

ML20079G092
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
ML20079G094	List: ML20079G092 ML20079G104
References
NUDOCS 9110080407
Download: ML20079G092 (33)

Text

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( - J oowners Grove,liknois 60515 V September 30,1991 Dr. Thomas E. Murley, Director Offlen of Nuclear Reactor Regulation U.S. Nuclear ReDulatory Commission Washington, D.C. 20555 Attn: Document Control Desk

Subject:

Quad Cities Nuclear Power Station Units 1 and 2 Application for Amendment to Facility O) erat!ng Licenses DPR 29 and DPR 30, Append x A, Technical Specifications Technical Specification Upgrade Program NBC Docket Nos< 50:254,and 50 26L Dr. Murley:

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 existin0 i mprovement 31ans, identif ying potential weaknesses and prioritizing improvement actions.

flecessary 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 amendment. 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 OperatinD Licenses DPR 29 and DPR 30. The proposed amendment reflects Commonwealth Edison's efforts to upgrade the following existing Technical Specification S3ctions: 3.2/4.2 "Protectivo instrumentation",3.9/4.9 " Auxiliary Electrical Systems". 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.  % En. :tive Su~ nary of the Technical Specification Upgrade Program and the prop ' sed amu,)dment;

2. A cumr ary of the changes;

3. A detailed description of the changes;

4. The proposed Technical Specification pages with the requested changes;

5. The existirr; h.'hnical Specification pages for DPR 29, are marked-up to reflect the ippro, " late changes to the existing bases sections.

6. CommonweA ddison's evaluation pursuant to 10 CFR 50.92(c) and 10 CFR 51.21; and,

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

Specifications. v i g C4f9fi445 7. WOR 8Mf M,8Mb P PDR O)V 1

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Dr. Thomas E. Murley S9ptember 30,1991 The proposed amendment has been reviewed and approved by Commonwealt1 Edison's on site and off site review in accordance with Company procedures.

The Technical Saecification Upgrade Program proposes changes to each toction of the existing Technical Specifications. As such, Commonwealth Edison ret uests that the proposed amendments be approved and issued as one document rat 1er 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 and 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 practico 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, s/

t Rita Stols Nuclear Licensin0 Administrator Enclosure (A): 3.2/4.2, " Protective Instrumentation" (B): 3.9/4.9," Auxiliary Electrical Systems" cc. A.B. Davis, Regional Adm!nistrator L.N. O!shan, Project Manager T.E. Taylor, Senior Resident inspector Illinois Department of Nuclear Safety d _ . ~ . - ~,

State of b/[, , County of Ch[ " o r n c m. tu. <

Signed.before me on thisikf day Se a C t m  ?

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QUAD CITIES NUCLEAR POWER STATION TECHNICAL SPECIFICATION UPGRADE PROGRAM PROPOSED AMENDMENT SECTION 3.2/4.2 " Protective Instrumentation" WW W W WW 6 mue M "

EXECUTIVE

SUMMARY

Proposed Changes to TS 3.2/4.2

' PROTECTIVE INSTRUMENTATION

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EXEEllTlR.DMMAhX QUAD CITIED TECHNICAL SPECIPIchTIoH UPGRADE PROGRAM The Quad Cities Technical Specification Upgrado Program was conceptualized in responuo to lessons learned from the Drenden 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 a safe operation of the plant and, therefore, only an upgrade was deemed appropriate.

The comparison study revealed a mix of recommended upgrades which included the relaxation of certcin existing Technical Specification requir9ments, the addition of surveillances, the removal of M1owances which would no longer be allowed under new plant licensing, and better definition of appropriate action requirementr 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 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 practicos. The upgraded specifications provide for more safe and reliable operation of the plant. The program improves the operstor'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 i is the addition of equipment operability requirements during shutdown conditions.

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EXEP_TIVE

SUMMARY

(09At1DM A1.

Proposed Technical Specification Section 3.2/4.2, " Protective Instrumentation" The proposed change deletes the present objective statement and provides Applicability statements within each specification 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. The bases of the technical specifications are relocated to the end of the section. Tables and figures are now 2ocated af ter the LCOs and before the bases.

The proposed changes to Specifications 3.2.A/4.2.A through 3.2.H/4.2.11 represent a blend of requirements from tae present Quad Cities Technical Specifications and that of later operating BWR plants.

Included in the proposed specification are operability requirements for a drywell .agh radiation isolation which had previously been added to the plant by design change per NUREG-0737.

Proposed changes to Tables 3.2-1 through 3.2-6 and 4.2-1 -

through 4.2-4 do not altar any established setpoints or reduce the minimum operable channels per trip system requirements.

In accordance with the guidelines of Generic Letter 89-01 present Tables 3.2-5, 3.2-6, 4.2-3 and 4.2-4 and the prov1sions of Specifications 3.2.G/4.2.G end 3.2.H/4.2.H are relocated to the ODCM (Offsite Dose Calculation Manual). The present requirements for the Steam Jet Air Ejectors are retained in the technical specifications.

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SUMMARY

OF CHANGES PROPOSED TS 3.2/4.2

' PROTECTIVE INSTRUMENTATION"

StDDU2X._QL CHAEGER Proposed Specification 3.2/4.2 Protective Instrumentation This sectjon contains proposed changes to Quad Cities Units 1 and 2 TechnicaA Specification Section 3.2/4.2. Some of the changos pron.3ed are made to improve readability and u;3ti,lity of the prese.nt technical specifications by incorporati.o a format simils.r to the standard Technical Specifications (STS). Other changes provide technical improvements by incorporating plovisions from other operating BWRs and/or the STS. The specific changes are described F-low.

Item 1:

Page 3.2/4.2-1 DPR-29 Delete the present Applicability and Objective sections at the beginning of Section 3.2/4.2. The Applicability statement is being included after the Limiting Conditions for Operation in each individual specification.

Iten 2:

Page 3.2/4.2-1, Specification 3.2.A/4.2.A, DPR-29

a. Present LCO 3.2.A is rewritten such that th( primary containment isolation actuation instrumentation is required operable with setpoints in accordance with Table 3.2-1 requirements,

b. A new Applicability section is added for primary nontainment isolation actuation ine&-*uientation to reference Table 3.2-1 for applicable operat'.eht modes,

c. New Actions 1, 2, and 3 ae added and are model.ed after STS guidelines using Caneral Electric NEDC-31677P dated June 1969 as an updated guide.

d. New SR 4.2.A.2, modeled after STS guidelines, is adited to

. provide for logic system functional testing of primary containment isolation functions at least once each refueling outage.

Item 34 Page 3.2/4.2-1, Specification 3.2.B/4.2.B, DPR-29

a. Present LCO 3.2.D is rewritten such that the core and containment cool.ng systems actuation instrumentation is required operable with setpoints in accordance with Table 3.2-2 requirdments.

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b. A new Applicability section is added to reference Table 3.2-2 for applicable operational modes,

c. New Actions 1, 2, and 3 are added and are rodeled after STS guidelines using General Electric NEDC-30936P-A dated December 1988 as an updated guide.

d. New SR 4.2.B.2, modelod after STS cuidelines, is added to provide for logic system functional testing of the core and containmenc cooling functions at least once each refueling outage.

Item 4:

Page 3.2/4.2-1 and 3.2/4.2-2, Specification 3.2.C/4.2.C, DPR-29

a. Present LCO 3.2.C is rewritten to require the control rod block instrumentation operable with setpoints consistent with Tr!r Level Settings in Table 3.2-3.

b. An Applicability section is added to reference Table 3.2-3 for applicable operational modes.

. v Actions 1 and 2 are added and are modeled after STS idelines.

P asent Speci.~ cation 3.2.C.2 is moved to the Notes for

'2 ble 3.2-3.

T. cur ':

Page 3.2/4.2-2, 'pecification 3.2.D/4.2.D, DPR-29 The present technical specification requirements for the Refueling Floor Radiation Monitors are rewritten and rearranged to follow STS guidelinas for LCO, Applicability, and Action requirements. The proposed Applicability is the same as that for Secondary Containment Integrity in proposed Specification 3.7.1.

Item 6:

Ps .2/4.2-3, Specification 3.2.E/4.2.E, DPR-29 cenent technical specification requirements for the 9;a >: .ccident Instrumentation are rewritten and rearranged to cliow STS guidelines for LCO, Applicability, and Action requirements.

Item 7:

Page 3.2/4.2-3, Specification 3.2.F/4.2.F, DPR-29

a. The present technical specification requirements for the Control Room Ventilation System Isolation function are

rewritten and rearranged to follow STS guidelines for LCo, Applicability, and Actions. A trip setpoint is added for the radiation detection instrumentation in the Reactor Building Ventilation Exhaust Ducts,

b. Two signaln that initiate isolation of the Control Room Ventilation System are not presently listed in the technical specifications. These signals are added to proposed Specification 3.2.F and are Drywell High Re.diation and Refueling Floor Radiation Monitors.

c. New Applicability of at all times is added for the Toxic Gas detection instrumentation and all Operational Modes and while handling irradiated fuel in the reactor building for the High Radiation in the Reactor Building Ventilation Exhaust detection instrumentation. The Applicability for the Refueling Floor Radiation Monitors references proposed Specification 3.2.D. The Applicability for the Drywell High Pressure, Reactor Low Water Level, Drywell High Radiation, and Main Steam Line High Flow isolation instrumentation references Table 3.2-1 provisions,

d. New Action requirements are added based on STS guidelines and present plant requirements to isolate the control room ventilation system. Proposed Actions for the Refueling Floor Radiation Monitors reference Specification 3.2.D.

Item 8:

Pages 3.2/4.2-4 and 3.2/4.2-5, Specifications 3.2.G/4.2.G and 3.2.H/4.2.H, DPR-29 Present Specifications 3.2.G/4.2.G, " Radioactive Liquid Effluent Instrumentation," and 3.2.H/4.2.H, " Radioactive Gaseous Effluent Instrumentation," requirements are-deleted and relocated to the ODCM to allow implementation of Generic Letter 89/01. New Section 3.2.G/4.2.G is added to retain the Steam Jet Air Ejector (CJAE) technical specifications as follows:

a. Present TaDie 3.2-6 requirements for the SJAE Radiation Monitors are used for the LCO, Applicability and Action provisions. Present Table 3.I-6 is deleted,

b. Present Table 4.2-1 is referenced for the functional test, calibration and checks required for the SJAE radiation monitors. Present Tables 4.2-1 and 4.2-4 contain the same surveillance requirements for these monitors except for the source checks which are added as new surveillance Requirement 4.2.G.2. Table 4.2-4 is deleted.

Item 9:

Pages 3.2/4.2-6 through 3.2/4.2-14, DPP-29

a. Renumber the Bases pages to allow placement at the end of Section 3.2/4.2.

b. Rewrite the Bases, ss necessary, to allow implementation of the proposed changes to the technical specifications,

c. In the Surveillance Requirements Bases, delete the description of the method used to determine the miriimum functional testing frequency in accordance with Reference 1.

Reference 1 is an outdated document and is no longer used to determine surveillance testing intervals. Add a description of the methods currently used to determine surveillance testing intervals.

Item 10:

Pages 3.2/4.2-15 and 3.2/4.2-16, Table 3.2-1, DPR-29

a. The present columns for Table 3.2-1 are reordered such that the Trip Function is the first column and the Minimum operable Channels per Trip System column is the third column. New columns are added for Valve Groups Operated by Trip Function as column two and Applicable Operational Modes as column S. The Trip Level Setting is column 4 and the Action is column 6.

b. The Applicable operational Modes are given as 1, 2, or 3.

c. The names of several Trip Functions are changcd such that the noun appears first, i.e., "High Drywell Pressure" is changed to "Drywell High Pressure", etc.

d. Added new primary containment isolation signals for RCIC and HPCI Steam Supply Line Low Pressure and Drywell High Radiation.

e. The present Minimum Number of Operable or Tripped Instrument l Channels reflect the total number of instruments required l operable for both trip systems. The proposed change indicates the number of operable channels required for one l trip system.

f. Present Note 2 to Table 3.2-1 contains the Actions to be taken when the minimum operable channels requirement cannot L be met-for one or both trip systems. The Action to be taken if the requirement cannot be met for one trip system has been moved to LCO Section 3.2.A. Present Actions A, B, C,

and D in Note 2 are moved from the Table notes and are l

placed immediately behind new Table 3.2-1 as Actions 11, 12, 13, and 14. Present Action B is rewritten using STS

guidelines for all Trip Functions except Main Steam Line Low Pressure where the present requirements are reworded using later operating plant provisions as Action 15. New Action 16 is added from STS guidelines for the Drywell High Radiation Trip Function.

g. Present Note 1 is rewritten as proposed Note (a) following STS guidelines. Present Note 4 is changed to state that the Main Steam Line Low Pressure isolation is bypassed when the mode switch is not in Run instead of the present provision of being bypassed in Refuel er Startup/ Hot Standby. Present Note 5 is changed to state that the Main Steam Line Tunnel High Radiation Trip Punction also isolates the mechanical vacuum pump suction line instead of the discharge line isolation valves. New Notes (h), (i) and (j) are added to Table 3.2-1. New Note (h) implements requirements from General Electric Topical Report NEDC-31677P-A dated June 1989 for allowable outage times for performing surveillance tests. New Note (i) references Table 3.7-1 in order to determine the valves associated with each valve group. New Note (j) states that the Trip Functions of Main Steam Line High Flow, Main Steam Line Tunnel High Temperature and Main Steam Line High Radiation are required operable in Operational Modes 2 and 3 only when any main steam line is not isolated.

Item 11:

Pages 3.2/4.2-17 and 3.2/4.2-18, Table 3.2-2, DPR-29

a. The present columns for Table 3.2-2 are reordered such that the Trip Function is the first column and the Minimum Operable Channels per Trip System is the second column. New columns are added for Applicable operational Modes as column 4 and Action as column 5. The Trip Level Setting is column

3. The present remarks column is deleted.

b. The Applicable operational Modes are given as 1, 2, 3, 4, or 5.

c. The present Minimum operable or Tripped Instrument Channels requirement lists the total number of instruments required operable for both trip systems. The proposed change lists the number of instruments required operable per trip system.

d. Present Notes 1 and 5 to Table 3.2-2 contain the actions to be taken when the minimum operable channels requirement cannot be met for one or both trip systems. These Note 1 and 5 Actions are rewritten as Actions 20 through 23 and are moved to a separate page immediately following new Table 3.2-2. The new Actions are modeled after STS guidelines using General Electrical NEDC-30936P-A as an updated guideline. The first part of present Note 1 is rewritten as new Note (a).

e. New Table Notes (c), (f), (g) and (h) are added.

Item 12:

Pages 3.2/4.2-19 and 3.2/4.2-20, Table 3.2-3, DPR-29

a. The present columns for Table 3.2-3 are reordered such that the Trip Function is the first column and the Minimun.

Operable Channels per Trip Function is the second column. A new column is added for Applicable Operational Modes as column 4. The Trip Level Setting is column 3 and the Action is column 5.

b. The Applicable operational Modes are given as 1, 2, 3, 4, or 5.

c. Rod Blocks for S.sd, IRM, RBM, and APRM Inoperative are added following STS guidelines.

d. The present Minimum operable or Tripped Instrument Channels per Trip System requirement lists the number of instruments required operable for each of the-assumed two trip systems.

The rod block function consists of only one trip system and new column 2 listing of Minimum Operable Channels per Trip Function reflects this system design.

e. Present Note 1 to Table 3.2-3 contains the actions to be taken when the minimum operable channels requirement cannot be met. These Note 1 Actions are rewritten using STS guidelines as Actions 30, 31, and 32 and are moved to a separate page immediately following new Table ?.2-3. Part of present Note 1 is used to write proposed Note (f) to specify that the RBM is automatically bypassed at less than 30%

Rated Thermal Power or when a peripheral rod is selected

f. Present Notes (5), (7) and (8) are deleted.

g. New Table Notes (a), (g), (j), and (k) are added. These Notes are modeled after STS requirements and present Quad Cities Technical Specification requirements for RBM operability. Proposed Note (j) on RF,M operability is changed from present requirements to clarify that the allowance for one less channel to be operable for

. maintenance and/or testing applies only during a. limiting control rod pattern.

Item 13:

Pages 3.2/4.2-21, 3.2/4.2-22, and 3.2/4.2-23, Table 3.2-4, DPR-29

a. Changes to Table 3.2-4 includo deletion of the present columns on Instrument Readout Location, Number provided, and Range. The Minimum Channels operable for each variable are changed to ensure availability with postulated single

failures. New columns are added for Applicable Operational Modes and Action,

b. Applicable Operational Modes are added as 1 and 2. The Applicable Operational Modes for Drywell Radiation Monitor  !

are expanded to include Mode 3 following the STS guidelines. I

c. Items listed are revised to be consistent with the STS by being Regulatory Guide 1.97, Type A and Category 1 variablese Drywell oxygen concentration is added while torus air temperature, torus pressure, neutron monitoring,

. drywell temperature and torus water level (narrow range) are deleted instruments, not classified as essential in determining whether the plant safety functions are being performed. Torus to drywell differential pressure is relocated to 3.7.E with LCO and actions requirements essential to that function.

Item 14 Pages 3.2/4.2-24 through 3.2/4.2-26, Tables 3.2-5 and 3.2-6, l DPR-29 '

Present Tables 3.2-5, " Radioactive Liquid Effluent Honitoring Instrumentation," and 3.2-6, " Radioactive Gaseous Effluent Monitoring Instrumentation," are deleted in order to implement the provisions of Generic Letter 89/01. Except for the SJAE requirements, the contents of Tables 3.2-5 and 3.2-f are relocated to the ODCM. The SJAE requirements presently contained in Table 3.2-6 are placed in proposed Specification 3.2.G.

Item 15:

Pages 3.2/4.2-27, 3.2/4.2-28, and 3.2/4.2-29, Table 4.2-1, DPR-29 i-

a. The present Instrument Channel column on Table 4.2-1 is changed to Trip Function to match the same column name on Table 3.2-1, 3.2-2, and 3.2-3. A new column for Applicable Operational Modos is added to match requirements for operability of the instruments with requirements to perform surveillance requirements. The present columns titled Instrument Functional Test, Calibration, and Instrument Check are changed to Channel Functional Test, Channel Calibration, and Channel Check, respectively.

b. The present monthly functional test requirement for ECCS Instrumentation for Reactor Low Low Water Level, Drywell High Pressure, Reactor Low Pressure, Containment Spray

, Interlocks of 2/3 Core Height and Containment High Pressure, and Low Pressure Core Cooling Pump Discharge Pressure is changed to quarterly in accordance with General Electric Topical Report NEDC-30936P-A.

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c. Rod Block SRs for SRM, IRM, RBM, and APRM Inoperative are added following STS guidelines and General Electric Topical Report NEDC-30851P, Supplement 1. Additionally, STS provisions for Weekly functional testing of the IRM and SRM trip f'. actions while in Mode 2 and 5 are adopted. The present monthly functional test requirement for Rod Block trip functions of APRM Upscale (flow bias), APRM Downscale, RBM Downscale and RBM upscale is changed to quarterly in accordance with General Electric Topical Report NEDC-30851P, supplement 1.

d. The present monthly functional test requirement for the Control Room Ventilation System Isolation trip functions of Reactor Low Water Level, Drywell High Pressure, and Main Steam Line High Flow are changed to quarterly in accordance with General Electric Topical Report NEDC-31677P.

e. The present Note 1 and Note 4 functional test requirement for the Main Steam Line Isolation trip functions of Main Steam Line High Flow, Main Steam Line Low Pressure, and Reactor Low Low Water Level are changed to quarterly in accordance with the guidelines of General Electric Topical Report NEDC-31677P.

f. The present Note 1 functional test requirements for the HPCI Isolation trip functions of HPCI Steam Line High Flow and HPCI Steam Supply Line Low Pressure are changed to quarterly in accordance with the guidelines of General Electric Topical Report NEDC-31677P.

g. The present Note 1 functional test requirements for the Steam Jet Air Ejector trip function of Off-Gas Radiation Monitors is changed to quarterly in accordance with the guidelines of General Electric Topical Report NEDC-31677P.

h. The present Note 1 functional test requirements for the Reactor Build $ng Ventilation System Isolation and SBGTS Initiation trip function of Refueling Floor Radiation Monitors is changed to quarterly in accordance with the guidelines of General Electric Topical Report NEDC-31677P.

i. Present quarterly Channel Calibrations are retained. Present Channel Calibration frequency of Refueling for Rod Block trip functions APRM Upscale (flow bias) and RBM Upscale are changed to quarterly in accordance with STS guidelines.

Present calibration frequency of during each startup or controlled shutdown for the IRM Downscale and Upscale, and the SRM Downscale and Upscale functions are changed to quarterly in accordance with STS guidelines. A quarterly Channel Calibration is added to the Scram Discharge Volume (SDV) High Water Level in accordance with STS guidelines.

j. Prcsent Notes 1 and 4 on Table 4.2-1 are deleted. Present Note 3 is used to replace Note 4. Present Note 3 is deleted from the SRM Detector Not in Startup Position since the functional testing of this function is actually performed by partial withdrawal of the instrument. Present Note 10 is replaced by Note (p) and changed to require Trip Unit Calibration at least once per 92 days based on General Electric Topical Report NEDC-31677P. New Notes (g), (h),

(1) , ,(j) , (k), (1), (m), (o), (q), (r), (s) and (t) are added.

k. Add the Drywell High Radiation isolation function and the Reactor Building Ventilation Exhaust Duct Radiation Monitors surveillance requirements.

1. Present Channel Check frequencies are changed to at least once per shift. In addition, a Channel Check frequency of at least once per shift is added to the containment spray Interlock of 2/3 Core Height.

Item 161 Pages 3.2/4.2-30 and 3.2/4.2-31, Table 4.2-2, DPR-29

a. On Table 4.2-2 the present columns of Minimum Number of Operable Channels and the Instrument Readout Location are deleted. The present column titled Parameter is changed to Instrument and a new column for Applicable Operational Modes is added. The variables listed are made to be consistent with the proposed Table 3.2-4. Torus to drywell differential pressure is relocated to 4.7.E to support that function,

b. The Applicable Operational Modes of 1, 2 and 3 used on Table 3.2-4 are implemented on Table 4.2-2 in order to match surveillance and operability requirements.

c. Present Table 4.2-2 notation "*" is deleted. Notations "**"

and "***" are converted to Table Notes (a) and (b). The reference to post-maintenance testing in present notation

"**" is deleted.

d. Present quarterly and refueling interval Channel Calibration tests are retained. Present daily and monthly Channel Checks are changed to monthly in accordance with STS guidelines. The proposed Channel Calibration and Channel check for drywell oxygen concentration are quarterly and monthly respectively to be consistent with the hydrogen monitoring equipment and current Station practice, l

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Item 174 Pages_3.2/A.2-32 through 3.2/4.2-34, Tablen 4.2-3 and Tables 4.2.4, DPR-29 Present Tables-4.2-3, " Radioactive Liquid Effluent Monitoring Instrumentation-Surveillance Requirements," and 4.2-4,

" Radioactive Gaseous Effluent Monitoring Instrument & tion Surveillance Reinirements," are deleted in order to implement the provisions of Ger.oric Letter 89/01. Except for the SJAE-requirements, the contents of Tables 4.2-3 and 4.2-4 are relocated to the ODCM. The present Surveillance Requircrants for '

the SJAE are retained in-Table 4.2-1 and in propo ed Specification 4.2.G.

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' PROTECTIVE -INSTRUMENTATION" e

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DESCRIPTION OF PROPOSED. AMENDMENT _ REQUEST Proposed Specification 3.2/4.2 Protective Instrumentation The changes proposed in this amendment request are taade to 1) improve the understanding and usability of the present technical specifications, 2) incorporate technical improvements and commitments, 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.

Item 1 The present Quad Cities technical specifications contain Applicability and Objective statements at the beginning of most sections. 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 objet: ive 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 2 Present Specification 3.2.A references Table 3.2-1 for the Limiting Conditions for Operation (LCO) for the instrumentation that initiates primary containment isolation. The proposed change rewrites the LCO for Specification 3.2.A with a new Applicability section that will reference Table 3.2-1 for primary containment isolation instrumentation operability requirements.

The proposed format for Specification 3.2.A follows STS guidelines while retaining the present two column page layout.

The proposed Actions for LCO 3.2.A follow STS guidelines and

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implement allowed out of cervice times and changes to Action requirements from General Electric NEDC-31677P dated June 1989.

Proposed Action 1 adds requirements not presently stated in the technical specifications. Proposed Action 1 will require that a channel be declared inoperable if the setpoint is less conservative than the value in the Trip Level Settings column of Table 3.2-1. Proposed Action 2 rewrites prewent Note 2 to Table 3.2-1 for the case where the minimum operable channels requirement is not met for one trip system. Action 2 follows the

, guidance provided in NEDC-31677P and allows additional time over

/ STS provisions in order to place inoperable inst mentation in trip before taking additional action. This additional time has

been:found acceptable by FhC SER and has been evaluated by Commonwealth Edison and found acceptable for use at Quad Cities Units 1 and 2.

Proposed Action 3 rewrites the part of Table 3.2-1 Note 2 that pertains to two trip systems by using the guidance provided in NEDC-31677P. -Action-3 allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place one trip system in trip and requires taking the Action in Table 3.2-1. The exception to these requirements would allow the trip system not to be tripped if that would cause the isolation to occur.

Item 3 Present Specification 3.2.B references Table 3.2-2 and Specification 3.5 for op,rability requirements for the instrumentation that initiates and controls the Core and Containment Cooling-Systems. The proposed change will rewrite the LCO for Specification 3.2.B with a new Applicability section that will reference Table 3.2-2 for Core and containment Cooling Actuation Instrumentation operability requirements. The proposed Applicable Opcrational Modes column on Table 3.2-2 will allow matching instrumentation operability requirements with actuated equipment operability requirements in Section 3.5.

The proposed Actions for LCO 3.2.B follow STS guidelines and include the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance (General Electric Topical Report NEDC-30936P-A) to restore inoperable instrumentation before taking the Action required by Table 3.2-2. Proposed Action 1 adds requirements not presently _ stated in the technical specifications.

Proposed Action 1 will require that a channel be declared inoperable if the setpoint is less conservative than the value in .

the Trip Level Settingr column of Table 3.2-22 Prepnseu Action 2 ,

-follows.STS guidelines and requires tttat.thh Action in Table-3.2-2 be taken with one or more channels inoperable. Proposed Action 3.provides steps to be taken with either Automatic Pressure Relief trip system inoperable. -Action 3 requirements are taken from similar STS reauirements and add more restrictive requirements not presently in the technical specifications.

Item 4-

_Present Specification 3.2.C.1 references Table 3.2-3 for operability requirements for the Control Rod Block Actuation Instrumentation. The proposed change will rewrite the LCO for-Specification 3.2.C with a new Applicability Section that will

-reference Table 3.2-3 for operability requirements for Control Rod Block Actuation Instrumentation.

Specification 3.2.C.2 presently contains requirements for minimum number of operable instrument channels for the rod block monitor.

These provisions are proposed to be moved to Table 3.2-3 as Table Note-(k). The location of these provisions in Table 3.2-3 will

. . .~ . - - _ - - . -

promote ease of use of the Technical Specifications without changing or reducing present requirements.

Proposed Actions 1 and 2 are modeled after STS provisions and provide assurance that Control Rod Block Instrumentation is maintained operable when required to perform its design function.

Item 5 The present wording of Specification 3.2.0 for the Refueling Floor Radiation Monitors is rearranged by this amendment request to follow an STS format. The present requirements are retained in the new LCO, Applicability, and Action sections. The proposed Applicability for Specification 3.2.D is the same as for Secondary Containment Integrity of when irradiated fuel or the fuel cask is-being handled in the reactor building, during Core Alterations and during operations with a potential for draining the reactor vessel. A provision is added to proposed Specification 3.2.D Actions such that the provisions of Specification 3.0.C ere not applicable if the Action requirements are not met. Inoperability of the Refueling Floor Radiation Monitors does not affect reactor operation and should not require a change in plant conditions.

Item 6 The present wording of Specification 3.2.E for the Postaccident Instrumentation is rearranged by this amendment request to fol' low an STS format. The present requirements are retained in the new Leo, Applicability, and Action sections.

Item 7 Specification 3.2.F/4.2.F presently contains requirements for operability of tha Control Room Ventilation System Isolation Instrumentation. The proposed changes implement an STS format and add Applicability and Action requirements. A trip setpoint of < 2 mr/hr is added for the high radiation detection instrumentation in the Reactor Building V6ntilation Exhaust Ducts.

The proposed changes' add two signals for completeness. These two signals are Drywell High Radiation and Refueling Floor Radiation Monitors. The operability requirements for Drywell High Radiation are contained in proposed Table 3.2-1 and those for the Refueling Floor Radiation Monitors are contained in proposed Specification 3.2.D. The proposed Applicability of at all times is appropriate for the toxic gas detection instrumentation since events of this nature can occur in any plant operating mode. The proposed Applicability of all Operational Modes and while handling irradiated fuel in the reactor building is appropriate for the high radiation detection instrumentation in order to ensure operability whenever there is a potential for a radioactive release that can reach the control room ventilation

system. The proposed Actions for an inoperable toxic gas and/or high radiation detection instrumentation are based on present plant operating practice which result in manually isolating the control room ventilation system if the instrumentation is not restored to operable status within prescribed time limits.

Item 8 In order to implement the guidance of Generic Letter 89/01, present Specifications 3.2.G/4.2.G, Radioactive Liquid Effluent Instrumentation and 3.2.H/4.2.H, Radioactive Gaseous Effluent Instrumentation, are deleted and their requirements relocated to the ODCM. Also, present content of Tables 3.2-5, 3.2-6, 4.2-3 and 4.2-4 are relocated to the ODCM with the exception of the SJAE specifications. The SJAE requirements in present Tables 3.2.6 and 4.2-4 are rewritten as Specification 3.2.G/4.2.G.

Item 9 The proposed changes to the Bases, relocates then to the end of l Section 3.2/4.2. This move will place the most important material first and make it more readily accessible to the user.

The changes to the present Bases include deletion of the outdated methods described to determine the minimum functional testing frequency in accordance with Reference 1. A description of the methods currently found acceptable to determine functional testing frequency is provided as the proposed change. Other

changes are necessary to support the proposed changes to Technical Specification Section 3.2/4.2.

l Item 10 1

l This item contains the proposed changes to Table 3.2-1. The present order for the columns in Table 3.2-1 is char.ged such that the Trip Function is first and the Minimum Operable Channels per Trip System is the third column. This change is proposed in order to make the tables more user friendly since the Trip Funct'.on is the first item looked for in these Tables before looking for operability or other information. New columns are added to Table 3.2-1 for Valve Groups Operated by Trip Function and Applicable operational Modes. The new column for Valve l Groups Operated by Trip Function provides the user with the isolation valve groups that are operated by the Trip Functions

! listed in the table. The valves in the affected isolation valve l

groups can then be determined by referring to Table 3.7-1. The Applicable Operational Modes column provides the user with l operability information that is easy to read and understand.

Present operability requirementa for Primary Containment Isolation Instrumentation is whenever primary containment integrity is required. Primary containment integrity is required uy present Specification 3.7.A.2 when the reactor is critical or when the reactor water temperature is above 212 degrees F and f'tel is in the reactor vessel (except for low power physics l

l

tests). The proposed change to Specification 3.7.A.2 will require primary containment integrity in operational Modes 1, 2, and 3 in order to correspond to present specification intent and to allow implementation of the operational Mode language of proposed Table 1.2. The one exception to these operational Mode requirements is the Trip Function of Low Main Steam Line Pressure. As indicated by present Table Note 4, this Trip Function is bypassed in the Startup/ Hot Standby and Refuel positions of the reactor mode switch, thus making operational Mode l'the only one applicable.

The proposed change to place the noun first in each of the names for the Trip Functions is strictly an administrative change to provide consistency throughout the technical specifications.

New Trip Functions for RCIC Steam Supply Line Low Pressure and HPCI Steam Supply Line Low Pressure are proposed to Table 3.2-1 to achieve consistency throughout the Technical Specifications.

These signals are already shown in the hote to Table 3.7-1 as Group 4 and 5 isolation signals and listed in Table 4.2-1 for surveillance requirements. Commonwealth Edison contracted General Electric to calculate a new isolation setpoint based on the current SAFER /GESTR Analysis inputs. The calculations were performed utilizing methodology contained in NEDC-31336, " General Electric Instrument Setpoint Methodology," dated october, 1986.

The upper bounding limit for the isolation signal was 150 psig which is based on the SAFER /GESTR Analysis inputs. The-lower bounding limits of 95 psig (HPCI) and 50 psig (RCIC) were chosen based on GE experience to assure equipment protection. The recommended values for the nominal isolation setpoints are 100 psig (HPCI) and 60 psig (RCIC).

The drywell high radiation isolation signal _was added to Quad Cities Units 1 and 2 by design change in 1982. The addition of this isolation function was made in order to implement the recommendations of NUREG 0737, which requires that the means for sensing radiation levels in the drywell after an accident be installed, with indication in the control room and trip signals supplied to isolate non-essential systems which penetrate primary containment. A 1988 review of NUREG 0737 commitments revealed that although the system had been installed and maintained and that technical specifications were implemented to require operability of the post-accident monitoring function, the technical specifications addressing the isolation function were never submitted. -The design of the system is such that two radiation sensors are installed in wells outside the drywell containment wall. Correction factors are used to adjust the

indicated reading on the monitors for the thickness of the l drywell containment wall. Each of the radiation sensors feeds a i separate instrument channel consisting of the sensor and an l' indicating trip circuit which is located in the control room.

The module in the control room consists of an indicator, a downscale alarm, upscale alarm, and an upscale trip. The module is also equipped with a self test circuit to simulate a signal 1

~

.~_ - . , . - , . _ _ ~ - -

l from the_ sensor. The Primary-Containment Group 2 logic is set up with two-trip systems. Both trip systems must trip in order to have an isolation signal sent to the valves. Each of the drywell high radiation channels-feods a separate Group 2 trip system resulting in a trip system logic consisting of two out of two.

The valves that receive a Group 2 isolation signal are listed in Table 3.7-1.

-The addition of the drywell high radiation isolation function to Table 3.2-1 is made in order to provide a complete list of instrumentation that initiates primary containment isolation.

The Minimum humber of Operable Channels per Trip System is established as one since there are two instruments installed in the plant with each feeding a single trip system. The design of the trip systems is described above. The setpoint for the drywell high radiation isolation function is < 100 R/hr. This setpoint is sufficiently high enough to ensure actuation only when required in abnormal or accident situations. The drywell high rsdiation isolation signal provides a backup to the existing Group 2' isolation signals of reactor low water level and drywell hign_ pressure. With the reector at pressure, the Group 2 isolation signal should be first initiated by either the reactor low water level or drywell-high pressure signals. With the reactor-depressurized, the Group 2 isolation signL1 should come first from a reactor low water level signal. In a long term post accident situation,-the drywell high radiation isolation signal

-will help ensure that the primary containment remains isolated and that inadvertent-transfer of radioactive material outside of the primary containment is avoided. The proposed Action _16 for the drywell high radiation function requires the closure of affected system-isolation valves within one hour and declaring the affected systems inoperable. The proposed Action follows STS

,. guidelines..

The present column in Table 3.2-1 of Minimum. Number of Operable or Tripped Instrument Channels contains the number of channels for two trip systems. The proposed change to this column will reflect the number of channels for one trip system.

Present Table 3.2-1 Actions ".,-B, C, and D are modified to follow j STS guidelines and are renumbered as Actions 11, 12, 13, and 14.

Due'to the greater importance of Actions over Notes, the Actions page-precedes the Notes page. Present Action A requirements to initiate an orderly _ shutdown and be in Cold Shutdown in 24-hours are replaced with STS provisions to be 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 Cold Shutdown within the next_24 hours.

l _Present Action B requires that with less than the required channels for both trip systems, an orderly load reduction be initiated and the reactor shall be in Hot Standby within-8 hours.

The proposed change to present Action B relabels it as Action 12 and implements STS guidelines to-be in at least Startup with the associated isolation valves closed within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or be 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 Cold Shutdown within the next 24' hours. Present Action B requirements are rewritten

-.. . _ _ , .. .. __ . _ __-s - ___ _ .__._ _ _ _ _ _ _ ___

s l

using STS-guidelines as proposed Action 15 for the Main Steam Line Low Pressure. Trip: Function. New Action 15 requires the reactor.to be-in at least Startup within 6_ hours' . Present-Action CLis_ rewritten as proposed Action 13 and requires closure of the -

1 isolation valves in-the RCIC system within one hour. .Present Action D_is~ rewritten as proposed _ Action 14 and requires closure -

of.the isnlation valves'in the HPCI subsystem;within one hour.

. The proposed action time of one hour in Actions 13 and 14 is sufficient'to allow closure of affected system isolation valves for_.the'affected systems.

The proposed changes to Table 3.2-1 Notes include rewriting Note 1 as new Note-(a). New Note (a) requires two trip systems to be operable in the applicable operational modes unless otherwise '

-allowed by the Action provisions. This rewrito is necessary since Table 3.1-1 is being changed to contain-the applicable

- operational modes for the-listed Trip Functions. New Note'(h)_ r implements allowed outage times for all Trip Functions following General Electric Topical-Report NEDC-31677P-A guidelines. _The allowed outage times are for required surveillances without-having tc-place the Trip System in the tripped condition.- The

-proposed time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for all Trip Functions has been accepted by'the;NRC and reviewed and found acceptable for-implementation at Quad: Cities Nuclear Station. New Note (i) provides useful--

information to the user by referring to Table.3.7-1 to find _the

= valves associated-with the valve groups listed on Table 3.2-1.

~ New-Note (j) is used-in conjunction with-proposed Action 12 to-clarify. operability requirements of; Main Steam Line isolation Trip _ Functions _in Operational Modes 2 and 3.. Action 12 requires

-the plant to be-in'Startup within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> with-the isolation valves-closed or to be 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 intat least Cold Shutdown within the next 24. hours. 'If the

- isolation-valves are cioned while the plant is in Operational Modes- 2 or 3c, . Note (j) states that the instrumentation is no longer. required to be operable.- The rewrite of present Note 4: -

- involves an administrative-change that does not change-the present : intent.

- Present Note 4'is changed to proposed Note (b) and applies to the Main steau Line Low Pressure Trip Function by stating that this functioniis bypassed 1when the mode-switchlis not in Run instead of the;present provision of being. bypassed 11n Startup/ Hot Standby

. or Refuel. -Present-Note 6 is changed to proposed Note-(e) and states that the: Main Steam Line Tunnel High Radiation Trip .

Function automatically isolates the mechanical vacuum pump suction'line'instead of_the discharge line. This change is made to~more accurately reflect plant design.

. . Item 11 This-~ item contains the cnanges to Table 3.2-2 on Instrumentation that Initiates or Controls the core and containment Cooling

' ~

- Systems. As-in Table 3.2-1, the columns for Table 3.2-2 are ,

reordered with the Trip Function as the first column and new

columns for Applicable Operational Modes and Actions are added.

The present remarks column is deleted since it contains information that is not required to be in the technical specifications.

The present column for Minimum Number of Operable or Tripped Instrument Channels is changed to Minimum Operable Channels per Trip System. This change will ensure consistency in the technical specification instrument tables and allow an easier determination of trip system requirements. The present column contains the total number of channels for both trip systems while the new column will contain the number of channels in one trip system.

The Applicable Operational Modes for the Instrumentation that Initiates or Controls the Core and Containment Cooling Systems are based on operability requirements for the systems that the instrumentation ir.itiates or controls. The Applicable Operational Modes are 1, 2, and 3 for all the instrumentation and Modes 4 and 5 when the associated Core or Containment Cooling System is required to be operable in Refuel or Cold Shutdown.

Present Note 1 to Table 3.2-2 contains the Action provisions if the Minimum Operable Channels requirement cannot be met for one or both trip systems. The present Action requires the systems actuated to be declared inoperable and the Action provisions of the affected systems to be followed. Present Note 5 contains the Action to be taken when the Degraded Voltage on the 4 KV Emergency Buses channels are one less than the minimum required.

The proposed Action-provisions are rewritten using STS and General Electric Topical Report NEDC-30936p-A into new Actions 20 through 23. The new Actions require, where appropriate, that the initiated system be declared inoperable but also allow, where appropriate, the inoperable channel to be placed in the tripped condition. The proposed changes provide needed flexibility in the Action provisions with a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to repair' allowed out-of-service-time, while maintaining systems necessary for the Core or Containment Cooling function.

, The other changes to Table 3.2-2 Notes include the rewrite of the i first part of present Note 1 as new Note (a). New Note (a) requires two trip systems to be operable in the required operational modes for the specified trip functions unless j otherwise allowed by the Action provisions. New Note (e) is taken from the present "*" footnote and defines the top of active fuel as 360" above vessel zero. New Note (f) allows a channel to be placed in an inoperable status for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for required

! surveillance without placing the trip system in the tripped condition. This 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowance comes from General Electric l Topical report NEDC-30936P-A for BWR ECCS Actuation Instrumentation. New Note (g) refers to ECCS instrumentation operability in operational Modes 4 and 5. In operational Modes 4 and 5 the instrumentation is required operable only when the

(

{

associated Core or Containment Cooling System is required to be operable in Refuel or Cold ' Shutdown. New Note (h) refers to undervoltage instrurentation operability in operational Modes 4 and 5. In operational Modes 4 and 5 the instrumentation is required operable only when the associated essential 4 KV buses are required to be operable in Refuel or Cold Shutdown.

Item 12 This item involves proposed changes to Table 3.2-3 for Instrumentation that Initiates Rod Block. As in Table 3.2-1 above, the columns are reordered so that the Trip Function is column 1 and new columns for Applicable operational Modes and Action are added.

New provisions are added modeled after STS guidelines for SRM, IRM, RBM, and APRM Inoperative rod block trip functions.

Present Note 1 contains the Operational Modes for which the Rod Block Instrumentation is required to be operable. The Operational Modes have been added to Table 3.2-3 in the Applicable Operational Modes column with some changes using STS guidelines. The IRM and SRM functions are not required in Mode 1 since the APRM provides core monitoring capability at power. The RBM upscale la not required by present provisions to be operable at less than 30% rated thermal power which translates into only being required operable in Operational Mode 1. The RBM downscale is not required to be operable in Startup/ Hot Standby by present Note 1 provisions and thus ic only required operable in operational Mode 1. The RBM function is not required below 30%

rated thermal power as discussed in the present Bases for Specification 3.2. Therefore, the RBM downscale operability requirements are changed to match those for the RBM upscale, i.e., not required below 30% rated thermal power. The ApRM downscale and flow bias trips are not required by present Note 1 provisions to be operable in Startup/ Hot Standby and thus operability for these functions is only operational Mode 1. The Scram Discharge Volume High Water Level trips are required whenever control rods can be withdrawn which is operational Modes 1, 2, and 5; and the bypass rod blocks are active only with the reactor mode switch in Shutdown or Operational Modes 3 and 4.

The present column of Minimum Number of Operable or Tripped Instrument Channels per Trip System indicates that the Control Rod Block System contains more than one trip system. This inference in not correct since any rod block signal vill cause a control rod block; thus there is only one trip system containing all the trip channels. The proposed change will make the Table column the Minimum operable Channels per Trip Function and will reflect all the channels in the system rather than the present channels in one trip system. Present Note 5, that provides for the bypassing of one of four SRM inputs is deleted. To clarify the Minimum operable Channels per Trip Function for the SRM trip functions the minimum number is reduced by one to three in the

-w y ,--w -s y y

table. These changes follows STS guidelines and plant design for the control rod block system.

Present Table 3.2-3 Actions are contained in Note 1. These Actions are rewritten using STS guidelines as new Actions 30, 31, and 32. These new Actions reflect only one Trip System.

Changes to Table 3.2-3 Notes include the addition of Notes (a),

(g), (j) and (k). New Note (a) requires only one trip system to be operable and implements the change described above since the control rod block system contains only one trip system. Proposed Note (f) contains the provisions of present Note 1 to Table 3.2-3 concerning RBM operability requirements and adds the clarification that the RBM is automatically bypassed when a peripheral rod is selected. This addition of the RBM bypass upon selection of a peripheral rod reflects system design and does not involve any modifications or design changes. Note (g) clariiles that the Scram Discharge Vc une operability in Operational Mode S is requirod only with more than ons control rod withdrawn and is not required while performing CRD maintenance per Specification 3.10.D or 3.10.E. Note (j) contains the provisions of present Specification 3.2.C.2 concerning allowed outage time for maintenance and/or testing for the RBM. These present Note (j) provisions are clarified such that they apply only during a Limiting Control Rod Pattern. Note (K) clarifles SRM operability in Operational Mode 5 by requiring the 2 requirei SRMs to be those required operable by Specification 3.10.B.

Item 13 This item contains the proposed changes to Table 3.2-4 for Postaccident Monitoring Instrumantation. The changes are non-technical in nature and are modo to provide consistency with channes tn the other instrumentation tables and some STS provisions. The Instrument name is provided as the first column with new columns added for Applicable operational Modes and Actions. The proposed Minimum Channels Operable are change to ensure that essential information necessary for the operator is maintained with postulated single failures.

Regulatory Guide 1.97, Type A and Category 1 variables are retained and drywell oxygen concentration is added. Torus air temperature, torus pressure, drywell temperature, neutron monitoring and torus water level (narrow range) are deleted since these instruments have not been classified as essential in determine whether the plant safety functions are being performed.

Present Note 1 requires the Postaccident Instrumentation to be l

operable during power operation. This requirement translates into operational Modes 1 and 2 and as such is reflected in the Applicable Operational Modes Column of Table 3.2-4. The Drywell Radiation Monitor Applicable Operational Modes are expanded to include Mode 3 in accordance with STS provisions. Present Note 2 l indicates that provisions are made for local sampling and l monitoring of drywell atmosphere. Current Note 2 should be l deleted since this is not information that is necessary to 1

l

l l

specify Postaccident Monitoring requirements. Present Note 3 is revived to be consistent with STS action provisions as proposed Note 40. Present Note 4 is relocated to 3.7.E as an action for drywell suppression chamber pressure control instrumentation.

Rotes 5 and 7 are retained as proposed Actions 41 and 42.

Present Note 8 is modified to include drywell oxygen concentration as proposed Action 43. Present Note 6 is deleted and wide range torus level (RG 1.97 qualified) action is revised to be consistent with STS under Action 40. These reactor shutdown provisions that are being adopted help to provide consistency throughout the technical specifications and use provisions that have been proven at later operating BWR plants with systems similar to those at Quad Cities.

Item 14 Present Tables 3.2-5, " Radioactive Liquid Effluent Monitoring Instrumentation," and 3.2-6, " Radioactive Gaseous Effluent Monitoring Instrumentation," are deleted in order to implemer.t the provisions of Generic Letter 89/01. These table provisions with the ev.coption of SJAE provisions are relocated to the ODCM.

The SJAE provisions are retained in proposed Specification 3.2.G/4.2.G.

Item 15 Some of the changes proposed for Table 4.2-1 include modifications to present requirements in order to provide consistency with changes proposed to other instrumentation tables. These changes include relabeling the first column as Trip Function and adding a column for Applicable Operational Modes to match operability requirements with performance of surveillance requirements. In order to promote consistency in technical specification terminology, the present columns for Functional Test, Calibration, and Instrument Check are changed to Channel Functionhl Test, Channel Calibration, and Channel Check, respectively.

New surveillance requirements modeled after STS and NEDC-30851P, Supplement 1, are added for APRM, IRM, SRM, and RBM Inoperative trip functions. Additionally, STS provisions for Weekly functional tests of IRM and SRM rod block functions while in Modes 2 and 5 are adopted.

Other changes to Table 4.2-1 include implementing the functional test frequencies contained in General Electric Topical Reports for Isolation Instrumentation (NEDC-31677P), ECCS Actuation Instrumentation (NEDC-30936P-A), and Control Rod Block Instrumentation (NEDC-30851P Supplement 1). The functional tests for the Trip Functions listed below are changed from monthly to quarterly:

1. ECCS Instrumentation - Reactor Low Low Water Level, Drywell High Pressure, Reactor Low Pressure, Containment Spray

l l

Interlocks of 2/3 Core Height and Containment High Pressure, and Low Pressure Core Cooling Pump Discharge Pressure.

2. Rod Block Instrumentation - APRM Upscale (flow bias), APRM Downscale, RBM Downscale and RBM Upscale.

3. Control Room Ventilation System Isolation - Reactor Low Water Level, Drywell High Pressure and Main Steam Line High Flow.

4. Main Steam Line Isolation - Main Steam Line High Flow, Main Steam Line Low Pressure and Reactor Low Low Water Level.

5. HPCI Isolation - HPCI Steam Line High Flow and HPCI Steam Supply Line Low Pressure.

6. Steam Jet Air Ejector Off-Gas Isolation - Off-Gas Radiation Monitors.

7. Reactor Building Ventilation System Isolation and SBGTS Initiation - Refueling Floor Radiation Monitors.

8. Drywell High Radiation - Dryvell Radiation Monitors.

Note that present Note 1 to Table 4.2-1 allows the functional test frequency for the affect.ed parameters to be extended to quarterly using an outdated methodology which is being deleted by the changes proposed in this amendment request. Also, ft should be noted that the " Trip Level Settings" listed in proposed Tables 3.2-1, 3.I-2, and 3.2-3 are limiting sutpoints which are equivalent to " Allowable Values" in the STS. The actual plant setpoints are conservatively adjusted with respect to the Technical Specifications " Trip Level Settings" to accommodate the drift associated with the particular instrument and test interval. As such, revised results of instrument setpoint calculations required to accommodate the longer test intervals will result in changes to actual plant setpoints, but will not require further Technical Specification changer.

Commonwealth Edison Company participated in the BWR Owner's Group effort that produced the Topical Reports described above. As such, a plant specific analyses was performed to identify the differences between the parts of the Isolation, ECCS and Rod Block systems that perform trip functions in the Quad Cities Plant and these of the base case plant analyzed in the Topical Reports. These dif.*erences were analyzed and found to be acceptable or to be bounded by the base case. The additional time interval between tests resulting from the changes described in the Topical reparts vLil be f actored into the instrument setpoint calculatsarp for the affected instruments. If the setpoint calculatings so indicate, the setpoints will be conservatively adju6ted to accommodate the additional drift associated with the longer test interval or the test interval will not be extended.

1 i

The present quarterly Calibration requirements for the following Trip Functions are retainedt

1. ECCS Instrumentation - Reactor Low Low Water Level, Drywell High Pressure, Reactor Low Pressure, Containment Spray Interlock of Containment High Pressure and Low Pressure Core Cooling Pump Discharge Pressure.

2. Main Steam Line Isolation - Main Steam Line High Flow and Main Steam Line Low Pressure.

3. RCIC Isolation - RCIC Steam Line High Flow and RCIC Steam Supply Line Low Pressure.

4. Control Room Ventilation System Isolation - Reactor Low Water Level, Drywell High Pressure and Main Steam Line High Flow.

5. Refueling Floor Radiation Monitors.

'n addition, the present Rod Block Trip Function Channel

. Calibration frequencies are changed as follows:

1. APRM Upscale - from Refueling to Quarterly.

2. RBM Upscale - from Refueling to Quarterly.

3. IRM Downscale - from during each startup or during controlled shutdowns to Quarterly.

4. IRM Upscale - from during each startup or during controlled shutdowns to Quarterly.

5. SRM Upscale - from during each startup or during controlled shutdowns to Quarterly.

6. SRM Downscale - from during each startup or during controlled shutdowns to Quarterly.

The proposed changes to present Channel check frequencies are made in accordance with STS guidelines. Present Daily and Monthly Channel Checks are changed to shiftly. A once per shift Channel Check is added for the Containment Spray Interlock of 2/3 Core Height.

The proposed addition of the Drywell High Radiation surveillance requirements to Table 4.2-1 are made to help ensure operability of the monitors when required to perform an isolation function.

These radiation monitors were installed in the plant in 1982 and were placed on a once per operating cycle frequency for the functional tests and calibrations. This present testing frequency has been demonstrated to be adequate to maintain operability of the radiation monitors and, as such, the proposed channel functional test frequency of quarterly and the channel l

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i calibration test frequency of once per refueling outage should be acceptable test intervals. The daily channel checks are added in accordance with STS guidelines. The proposed quarterly channel functional test frequency follows General Electric Topical Report NEDC-31677P recommendations and is more frequent than the present once per operating cycle test frequency.

The proposed addition of the Reactor Building Ventilation Exhaust Duct Radiation Monitcra is made in order to provide a cornlete listing of isolation signals in Table 4.2-1. The proposed Quarterly Channel Functional Test frequency and the Refueling Channel Calibration Test frequency are taken from present requirements in Table 4.2-4. The proposed Channel Check frequency of shiftly is based on STS guidelines and replaces present daily requirements in Table 4.2-4. Proposed Applicability requirements reference through Note (u),

Applicability in proposed Specification 3.2.F for the Control Room Ventilation System and whenever Secondary Containment Integrity is required.

Changes to present Notes on Table 4.2-1 include deletion of Notes 1 and 4. Present Note 1 uses an outdated methodology for extending functional test intervals and Note 4 is not needed since present Note 3 implements equivalent requirements. Present Note 3 is deleted form the SRM Detector Not in Startup Position functional test requirement since actual movement of the detector is necessary to perform the test. New Notes added are Notes (g),

(h), (i), (j), (k), (1), (m), (o), (q), (r), (s), (t), and (u).

These new notes implement STS guidelines, provide consistency with Tables 3.2-1, 3.2-2, or 3.2-3, or provide information pertinent to implementation of the General Electric Topical Report used to extend functional testing intervals. Proposed Note (p) implements revised requirements for Note 10 based on General Electric Topical Report NEDC-31677P. Jote 10 and proposed Note (p) address systems with analog tilp units ti require trip unit calibrations more often and seperate from instrumentation system calibrations which are requt ed at least once per refueling outage.

Item 16 The proposed changes to Table 4.2-2 for Postaccident Monitoring Instrumentation are made to provide consistency with proposed changes to Table 3.2-4 and to implement some STn guidelines. The present columns of Minimum Number of Operable Channels and Instrument Readout Location are deleted. The Instrument Readout Location information is not needed to determine surveillance requirements and is thus deleted. The present column of Parameter is changed to Instrument to be consistent with Table 3.2-4 changes. A new column for Applicable Operational Modes is added to provide consistency between operability and surveillance requirements. Original instruments not meeting the Type A or Category 1 requirements of RG 1.97 are deleted and those instruments that are important to hydrodynamic loads are

e relocated to specification 4.7.E.

The Applicable Operational Modes for the a fvell Radiation Monitor are upgraded to the STS provision. of Modes 1, 2 and 3.

Present Table 4.2-2 Note "*" requires instrument channels,to be operable during power operation. Since Operational Modes 1, 2 and 3 are included in the new column for Applicable Modes, the present Note "*" can be deleted. Present Notes "**" and "***"

are. converted to Table Notes (a) and (b), respectively.

3 Present Channel Calibration frequencies are retained for these instruments. Present Channel Chock frequencies of daily and monthly are changed to match STS guidelines of rad.uly. The proposad Channel Calibration and Channel Check for drywell oxygen concentration are quarterly and monthly respectively. The proposed frequencies are consistent with the hydrogen monitoring oquipment and current Station practice for Comsip-Delphi H 2/0 2 monitors.

Item 17 Present Tables 4.2-3, " Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements," and 4.2-4,

" Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements," are deleted in order to allow the implementation of Generic Letter 89/01. The provisions of these tables are relocated to the ODCM with the exception of the SJAE provisions which are retained in the technical specifications in Table 4.2-1 and Specification 4.2.G.

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