ML20079H055
| ML20079H055 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 10/02/1991 |
| From: | Schrage J COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9110100105 | |
| Download: ML20079H055 (21) | |
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Ccmmtnwcalth Ediscn 1400 opus Place C'
Downers Grove,1111nois 60516 r
October 2,1991 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation
- U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Document Control Desk
Subject:
Quad Cities Nuclear Power Station Units 1 and 2 Supplement to A pilcation for Amendment to Facility Operatin Licenses DPR 29 alid DPR 30 Appendix A, Tec nical Specifications Technical Specification Upgrade Program NBO_ Docket.Nosm50:25 Land _50:205
Reference:
(a) R. Stols letter to NRC dated 6/20/91
Dear Dr. Murley:
As part of the Quad Cities Technical Specifications Upgrade Program, Operating L(a) submitted Commonwealth Edison's request for an amendment to 4,;
Reference icenses DPR 29 and DPR 30, Appendix A, Technical Specificatime Section 1.0 " Definitions" Subsequent to the above referenced letter, it was noted tha'. the proposed definition for " Primary Containment 1ntegrity" (definition 1.33) was nc( fully consistent with other proposed Technical Specifications sections.
This inconsistney has been rectified in the enclosed supplement to-reference (a).-
Re lacement page 1,0 7 to proposed Section 1.0, " Definitions" submitted in Reference (a is herein enclosed.
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' Dr Thomas E. Murley 2-October 2,1991 Also, to facilitate incorporation of this supplement, full revisions to sections
" Summary of Changes"," Description of changes", and "Sig"nificant Hazards Considerations and Environmental Assessment Evaluation are enclosed as replacements for their corresponding sections submitted in Reference (a).
Please direct any c uestions concerning this proposed amendment to J. Schrage at (708) 515 7c83.
Very truly yours,b (l( L. t 9.:7
'7lL (,7 e9 John L. Schrage Nuclear Licensing Administrator
Enclosure:
(A): Replacement page 1.0 7 to proposed Amendment to Technical Specification Section 1.0, " Definitions"
): Replacement section " Summary of Changes" l: Replacement Section " Description of Changes"
,,1: Replacement Section "Significant Hazards Considerations and Environmental Assessment Evaluation" cc: A. Bert Davis, Regional Administrator-Rill l
L.N. Olshan, Project Manager NRR T.E. Taylor, Senfor Resident inspector Ouad Cities Illinois Department of Nuclear Safety C'*I8 Of
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ENCLOSURE (A)
QUAD CITIES UNITS 1 &2 DPR-29 & DFR-30 PRES?UR2 BOUNDARY LEAEAGI 1.32 PRESGURE DOUNDARY LEAKAGE shall be leakago through a non-isolc1910 fault in a reactor coolant system component body, pipe wall or vossol wall.
PRIMARY _CQNTAINMENT INTEGRITY 1.33 PRIMARY CONTAINMENT INTEGRITY means that the drywoll and pressure suppression chambor are intact and all of the following conditions are satisfied a.
All manual containment isolation valves on lines panotrating the containment which are not required to be open during accident conditions are closed, except for valvos that are open under administrativo control as parmitted by Specification 3.7.P.
b.
At least ono door in each air lock is closed and scaled except no permitted by Specification 3.7.C.
c.
All automatic containment isolation valves are in compliance with the provisions of Specification 3.7.P.
d.
All blind flanges and manways are closed.
PROCESS CONTROL PROGRAM (PCP) 1.34 The PROCESS CONTROL PROGRAM shall contain the current formulas, sampling, analysis, test, and datorminations to be made to ensure that processing and packaging of solid radioactive wastos based on demonstrated processing of actual or simulated wot solid wastes will be accomplished in such a way as to assure compliance with 10 CFR Parts 20, 61, and 71, Stato regulationr., burial ground requirements, and other requirements governing the disposal of solid radioactive waste.
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ENCLOSURE (B)
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SUMMARY
QE CHAHQEH PROPOSED SPECIFICATION 1.0 DEFI'iITIONS This part of the voposed amendment request contains changes to Quad Cities Unih and 2 Technical Specifications Section'1.0 on Definitions.
S nua anges are proposed to existing definitions, one axisting de '...lon (" Surveillance Interval") is moved to Techrc. ;2 Jpecir. cation 4.0, and new definitions are added in accordance with STS guidelines.
All the definitions are arranged in alphabetical order and each definition is assigned a specific numerical designator.
New Tables are added for Operational Mode definitions and Surveillance Frequency definitions.
The specific changes are described below.
Paces 1.0-1 throuah 129-6, DPR-29 Item 1:
The present definitions that are changed by this amendment request are as follows:
a.
Present Definition 1.0.A,
" Alteration of the Reactor Core" is changed to the STS and some later operating plants definitkon for " Core Alteration".
b.
Present Definitions 1.0.E, 1.0.F, 1.0.G and 1.0 LL,
" Instrument Calibration, Instrument Check, Instrument Functional ',
' and Channel Functional Test " respectfully, are replacco tth STS versions of the definktions for Channel
. Calibration, Channel Check, and Channel Functional Test, c.
Present Definition 1.0 L,
" Modes of Operation", is changed to
" Mode Switch Interlocks".
The new definiticn describes the reactor modo switch positions and associated interlocks.
d.
Present Definition 1.0.M,
" Operable", is changed to " Operable
- Operability".
e.
Present Definition 1.0.P,
" Primary Containment Integrity", is modified to require all manual and automatic containment isolation valves to be in compliance with the provisions of Specification 3.7.F.
f.
Present Definition 1.0.Q,
" Protective Instrumentation Definitions" is changed by adding.the introductory phrase l
" Protective instrumentation definitions are as follows:".
g.
Present Definition 1.0.X,
" Secondary Containment Integrity" is iaodified to require the standby gas treatment system to be operable pursuant to Specification 3.7.K.
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Present Definition 1.0.BB
" Critical Power Ratio (CPR)" in modified to STS wording w1th the incorporation of a generic reference for the critical power correlation in place of a reload specific correlation, i.
Present Definition 1.0.CC
" Minimum Critical Power Ratio," is clarified per STS guidelin,es to be the smallest CPR which exists in the core, j.
Present Definition 1.0.GG, " Fraction of Rated Power (FRP)," is clarified by stating that the core thermal power is the measured core power.
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Present Definitions 1.0.JJ, " Process control Program," and 1.0.KK, "Offsite Dose Calculation Manual (ODCM)," are modified per Generic Letter 89/01.
1.
1An administrative change is proposed to many of the present definitions in order to prenote consistency in presentation of the definitions.
The definition term is repeated at the beginning of each definition _ paragraph.
Item 2:
-New definitions are added for the following terms:
a.
Action b.
Average Planar Exposure c.-
Average Planar Linear Heat Generaticq Rate d.
Identified Lenkage e.
Limiting Control Rod Pattern f.
Linear Heat Generation Rate (LHGR) 9 Operational Mode h.
Pressure _ Boundary-Leakage 1.
Physics Tests j.
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Site Boundary 1.
Unrestricted Area
Item 3:
New Table 1-1,
" Surveillance Frequency Notation", is added to the technical specifications.
Item 4:
New Table 1-2, " Operational Modes" is added to the technical specifications.
Item 5:
The provisions of present Definition 1.0.DD, " Surveillance Interval", are modified and moved to proposed specification 4.0.B.
The present provision that requires the total max { mum combined surveillance interval time for any 3 consecutive surveillance intervals not to exceed 3.25 times the specified interval, is deleted.
Item 6:
With the inclusion of proposed Table 1-2 on Operational Modes, the present Definition 1.0.Y,
" Shutdown", is no longer needed and is deleted.
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ENCLOSURE (C) l i
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DESCRIJILQ]i 112 PROPOSED h}iEN_QMEliT BEQQE_SI PROPOSED SPECIFICATION 1.0 DEFINITIONS The changes proposed in this amendment request for Section 1.0 of the Quad Cities Technical Specifications are made to provide a more complete listing of the definition terms, to provide improvements to certain STS definitions based on later operating BWR plants' terms, and to allow implementation of Generic Letter 89/01.
An item by item description of the proposed changes requested is provided :Jolow.
The Summary of Changes section can be referred to in order to reference back to a given change and its affected pages.
Item 1 Item 1 addresses the proposed changes to present definitions.
The present Definition 1.0.A for " Alteration of the Reactor Core" is changed to the STS and later operating definition of " Core Alteration."
The proposed change to present Definition 1.0.A clarifies the intent of present provisions by stating that the definition applies only when the reactor vessel head is removed and fuel is in the vessel.
The proposed definition of Core Alteration provides an exclusion for the undervessel replacement of incore instrumentation.
This exclusion from the provisions of the Core Alteration definition has been adopted at some later operating plants and provides necessary relief from the Alterations. placed on plant operations during actual Core restrictions The present definitions for Instrument Calibration, Instrument Check, Instrument Functional Test and Channel Functional Test (Radiation Monitor) are proposed to be replaced with STS definitions for Channel Calibration, Channel Check, and Channel Functional Test.
This change will delete the present outdated terminology that limits the definitions to the " Instrument" and does not include the entire " Channel."
Present Definiticn 1.0.L,
" Modes of Operation", is proposed to be changed to " Mode Switch Interlocks".
A new definition for Operational Modes is added which references new Table 1-2 to define the reactor mode switch positions and reactor coolant temperatures associated with Operational Modes.
The present definition for " Operable" is expanded to include
" Operability" as part of the Operable terminology.
This change follows STS guidelines and provides for consistency in word usage and definitions throughout the technical specifications.
l Current definition 1.0.P,inment" Primary Containment Integrity",
requires all manual conta isolation valves on lines connecting to the reactor coolant system or containment or containment which are not required to be open during accident conditions to be closed and all automatic containment isolation valves to be operable or deactivated in the isolated position.
Additionally, at least one door in each air lock is required to be closed and sealed and all blind flanges and manways are closed.
The proposed changes provide consistency between the definition of Primary Containment Integrity for all penetrations affecting the operability of primary containment and any exceptions to the requirements provided for in the individual proposed Specifications 3.7.C,
" Primary Containment Air Lock," and 3.7.F,
" Primary Containment Isolation Valves." Compliance with the provisions of Specification 3.7.C and 3.7.F actions will satisfy the isolation valve operability requirements for the definition of Primary Containment Integrity.
The proposed change to present Definition 1.0.Q,
" Protective Instrumentation Definitions" is administrative in nature and adds an intraductory phrase to improve readability.
Present Definition 1.0.X,
" Secondary Containment Integrity", is proposed to be changed to require the Standby Gas Treatment System to be operable pursuant to Specification 3.7.K requirements instead of the present provision that the Standby Gas Treatment System be operable.
The proposed change will allow the Standby Gas Treatment System to be in compliance with the Action Statements of Specification 3.7.K and meet the intent of operability for Secondary Containment Integrity.
Present provisions of Definition 1.0.X could be interpreted to require that both trains of the Standby Gas Treatment System be operable to meet Secondary Containment Integrity requirements.
The proposed change follows STS and later operating plant practices of allowing system operability to be determined by specific system specifications.
The proposed change to present Definition 1.0.BB,
" Critical Power Ratio (CPR)," is made to preclude future Technical Specification Definition revisions due to minor changes in the fuel manufacturer's critical power correlations.
The reload specific "GEXL" is replaced by " applicable NRC-approved critical power correlation".
The proposed changa follows STS and the Hope Creek Generating Station amendment published in 4870 FR, Vol. 56, No.
25, Wednesday 6, 1991.
The proposed change to present Definition 1.0.CC,
" Minimum Critical Power Ratio," is made to clarify present wording.
The present definition refers to the most limiting fuel assembly in the core; whereas, the proposed change rewords this statement to refer to the MCPR as the smallest CPR which exists in the core.
This clarification does not change the technical meaning of this definition.
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The change proposed to present Definition 1.0.GG, " Fraction of Rated Power," adds the clarification that the core thermal power is the measured core thermal power and not the actual core power.
This change does not change present intent but does clarify the wording for users of the Quad Citics Technical Specification.
Genaric Letter 89/01 was issued on January 31,ification provisions 1989, and contains the guidance for relocating the Technical Spec for Radiological Effluents to the Offsite Dose Calculation Manual and the Process Control Program.
The proposed changes to present Definitions 1.0.JJ, " Process Control Program," and 1.0.KK, "Offsite Dose Calculation Manual," are made in order to implement the guidance of GL 89/01.
Changes to other sections of the Quad Cities Technical Specifications in order to implement GL 89/01 are reflected in the changes proposed for those sections.
The proposed administrative change to the definitions will provide consistency of presentation by starting each definition paragraph with the defined term.
Item 2 Twelve of the newly proposed definitions are taken from STS guidelines and are added to the Quad Cities Technical Specifications to provide a more complete list of defined terms.
These additions represent new restrictions or clarifications not presently in the Quad Cities Technical Specifications.
Item 3.
Item 3 addresses the addition of Table 1-1,
" Surveillance Frequency Notation", to the Quad Cities Technical Specifications.
STS guidelines, current plant technical specification allowances and current plant operating practices were used to develop proposed Table 1-1.
The STS provides a definition of Refueling Cycle as at least once per 18 months (550 days).
Current plant interpretation of Refueling Cycle is provided by present Definition 1.0.0,
" operating cycle".
The present definition of " Operating Cycle" is the-interval between the end of one refueling outage for a particular unit and the end of the next subsequent refueling
-outage for the same unit.
The present definition of " Operating Cycle" is retained in proposed Table 1-1 to define the surveillance frequency for a refueling cycle.
In order to provide a surveillance frequency notation for those surveillances that are to be performed at 18 month intervals, the letter "E" is added to indicate a surveillance frequency of at least once per 18 months (550 days).
Item 4 l
Proposed Table 1-2,
" Operational Modes", implements present Quad l
Cities Technical Specification allowances, STS provisions, and I
later operating plant specification allowances.
Present
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Definition 1.0.L uses the terminology "Moceu of Operation" instead of the STS terminology of " Operational Conditions".
Since the present users of the technical specifications prefer the " Mode" terminology, Quad cities has elected to use the terminology
" Operational Modes" in Table 1-2 and throughout the technical specifications.
Present Quad Cities temperature conventions are retained for Operational Modes 1, 2,
3, and 4.
STS guideline of
< 140oF is used for Operational Mode 5.+ Proposed Table 1-2 Notes Ta) and (c) are taken from STS guidelines and provide a definition of the Operational Mode of " Refueling" and allows movement of the reactor modo switch to the Run or Startup/ Hot Standby positions to test switch interlocks.
Proposed Table 1-2 Note (b) is taken from later operating plants specifications and addresses the ccndition where there is no fuel in the reactor vessel.
In this condition, the reactor is considered not to be in any Operational Mode and the reactor mode switch may be in any position or inoperable.
This table note is necessary in order to provide operational flexibility in the case where all fuel is removed from the vessel and modo switch opera'oility could restrict planned maintenance or other activities.
Proposed Notes (d) and (e) for Table 1-2 are taken from STS guidelines.
Proposed Note (d) allows the reactor mode switch to be placed in the Refuel position while the plant is in Cold Shutdown to allow a single control rod to be removed from the reactor pressure vessel _in accordance with proposed Specification 3.10.D.
. Proposed Note (c) allows the reactor modo switch to be placed in the Refuel position while the plant is in Hot Shutdown or Cold Shutdown while a single control rod is being recoupled or withdrawn provided that the one-rod-out interlock in OPERABLE.
Item 5 Present Definition 1.0.DD, " Surveillance Interval," contains limitations on maximum allowable extensions to surveillance intervals.
These provisions are contained in Specification 4.0.B of the STS and this proposed change moves the applicable provisions of present Definition 1.0.DD to proposed Specification 4.0.B considering the implementati0n of Generic Letter 89-14.
On August 21, 1989, the NRC Staff issued Generic Letter 89-14 which l
removes the 3.25 limit from Specification 4.0.2 (4.0.B in Quad Cities Technical Specifications).
The NRC Staff concluded in this letter that the removal of the 3.25 limit results in a greater benefit to safety than limiting the use of the 25% allowance to i
extend surveillance intervals.
As discussed in the proposed changes to Section 3.0/4.0 of the Quad cities Technical Specifications, this provision of the Generic Letter will be adopted with the resulting deletion of present Definition 1.0.DD.
Item 6 Present Definition 1.0.Y,
" Shutdown," contains the Operational I
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Modes of Ilot Shutdown and Cold St.utdown.
Since the operational Modes are proposed to be defined in new Table 1-2, this definition
'is no longer needed and is deleted.
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ENCLOSURE (D)
EYAkUATION EQB DJRNIflpART t(AZARDE QQHalDXRATJ.QE PROPOSED SPECIFICATION 1.0 DEFINITIONS The proposed changes provided in this amendment request are made in order to provide Definitions consistent with later BWR olants and Quad Citles present and past operating practicos.
Tho' proposed changes also allow implementation of GL 89/01.
These changes have been reviewed by Commonwealth Edison and we believe that they do not present a Significant Hazards consideration.
The basis for our determination is documented as follows:
BASIS EQB HQ FIGNIFICA11T 11AZARDS CONSIDERATION Commonwealth Edison has evaluated this proposed amendment and determined that it involves no significant hazards consideration.
In accordance with the criteria of 10 CFR 50.92(c) a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility, in accordance with the proposed amendment, would not:
1)
Involve a significant increase in the probability or consequences-of an accident previously evaluated because:
The proposed changes to the definitions are made to clarify present requirements, allow changes that have been adol,ted at other operating BWRs, promoto consistency in understanding of the definition of terms, and to add definitions for terms used in the Quad Cities Technical Specifications that are not
-currently defined.
The use of the STS and some later operating plants' version of the Core Alteration definition will clearly define when this definition is applicable.
Some later operating plants have revised the Core Alteration definition to allow-an cxclusion to the definition for undervessel removal of incore instrumentation.
Incorporating this change to the Core Alteration definition for Quad Cities will allow maintenance to proceed without unnecessary restrictions on plant operation and without impacting core reactivity safety while the plant is in the refuel' condition.
The use of STS definitions for Channel Calibration, Channel Check, and Channel Functional Test will help to clarify the intent of the present definitions using the " Instrument" terminology.
The proposed changes to the Primary Containment and Secondary Containment Integrity definitions will clarify present operability requirements.
The intent of the present definitions la that the Primary Containment Isolation Valves and Standby Gas Treatment Systems be operable pursuant to the requirsments of tncir respective individual specifications.
Presenc definitions could be interpreted to be more restrictive than
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intended and as such the changes are proposed to clarify present requirements and as such do not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change to the definition for Critical Power Ratio (CPR) follcws STS guidelines and a later operating plant's version of the CPR definition.
To permit the loading of a new fuel design into the QCHPS reactor, the change in fuel design and supporting correlations will have been previously reviewed and approved by the NRC and the limiting transients previously evaluated in the SAR will have been re-analyzed for each reload design.
New core operating limits will have been generated and documented in the CORE OPERATING LIMITS REPORT (referenced in the Technical Specifications) to ensure that all safety criteria are met for all analyzed accidents and limiting transients.
Therefore, this change does not involve a significant increase in the probability of consequences of any accident previously evaluated.
The changes to the definitions for Fraction of Rated Power and Minimum Critical Power Ratio follow STS guidelines and do not change the technical intent of the present definitions.
The proposed changes to the definitions for Process Control Program and Of fsite Dose Calculation Manual follow GL 89/03 guidelines to expand the definitions to more clearly define the content of these documents with the deletion of RETS requirements from the technical specifications.
These changes do not involve a significant increase in the probability or consequences of any accident previously evaluated.
The addition of new terms to Section 1.0 provides the user of the technical specifications with easily accessible definitions that are currently accepted by other operating DWRs and are applicable to Quad Cities.
New Tables 1-1 and 1-2 allow arrangement of present Quad Cities requirements or interpretation of requirements into an STS format for case of use and availability.
Proposed Table 1-1,
" Surveillance Frequency Notation," uses some of the present Quad Cities interpretations of Surveillance Frequencies and does not relax or modify any existing testing intervals.
Proposed Table 1-2,
" Operational Modes," takes present requirements that are located in individual specifications and uses an STS format for arrangement of these provisions.
Present temperature limits for Operational Modes are retained except for Refuel where the STS limit of < 140oF is adopted.
Footnotes are added to provide clarification and to allow exceptions to Mode switch position where needed to allow for necessary testing and other operations.
Since the proposed addition of Tables 1-1 and 1-2 retains present operating restrictions and testing allowances or adopto proven STS guidelines that are applicable to Quad Cities, there is no increase in the probability or consequences of an accident previously evaluated.
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The applicable provisions of present Definition _1.0.DD,
" Surveillance-Interval" are being moved and retained in
-proposed Specification 4.0.B after considering implementation
~i of-Generic-letter 89-14.
The present provisions of Definition 1.0.Y,-" Shutdown," are proposed to be moved to new Table 1-2.
'The proposed _ movement-of these requirements provides a more user friendly document and retains necessary_ limiting provisions.
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Create theLpossibility-of a new or different kind of accident from any previously evaluated because:
-The proposed changes leave intact present operating philosophy
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and only implement new provisions where necessary to clarify-and_ ensure that'present allowances are understood and
-maintained.-
The proposed exception to the Core Alteration definition will' allow-undervessel replacement of incore-instruments without considering this an alteration of the core.- Duo to the small amount of fissionable material in these1 instruments, their= movement cannot create the
. possibility of a'new or different kind of-accident from any previously evaluated for--nuclear-safety.
The change from the " Instrument" philosophy-to the "Channe)"
philosophy for calibrations, checks and functional tests provides clarification of present wording and intent.
"he STS
" Channel" philosophy is being used at Quad Cities in any present applications and this technical specificativo change will ensuro-its consistent use for applicable testing
- functions.
The: proposed. changes'to the Primary Containment and Secondary Containment Integrity definitions are clarifications of intent
- with respect tx) operability provisions for Primacy Containment-Isolation Valves and Standby Gas Treatment Systems.
Primary Containment and:Socondary-Containment. Integrity requirements are considered to be-maintained while equipment z.nd systems are in the Action statements'of Specifications 3.7.C 3.7.F and'3.7.K.
The individual' equipment and system specifications
-contain allowed-outage provisions to ensure thht operability is maintained'within defined time limits, which are considered to be-sufficiently-short in_ duration, such that impact-is minimal tx) Primary or Secondary Containment Integrity
- onsiderations. - The proposed changes do not change system perability-requirements 1and as such do not create the
. possibility:of a new or different kind of accident.from_any previously evaluated.-
Use offa more generic reference " applicable NRC-approved critical: power correlation" in the Critical Power Ratio definition in place of a reload specific correlation like "GEXL" will not change the present intent of the definition but'only preclude the necessity to revise the Critical Power Ratio aefinition every-tine there are minor changes in the
fuel manufacturer's critical power correlations to support thuir new fuel design.
Provided that the changes to the critical power correlation are reviewed and approved by the NRC, no new or different accident, from any previously evaluated, is created by this broader definition.
Therefore, this change cannot create the possibility of a new or different kind of accident from any previously evaluated.
The changes to the definitions for Fraction of Rated Power and Minimum Critical Power Ratio do not change present intent and are made to clarify present requirements.
The changes to the definitions for PCP and ODCM are expansions of present provi no in order to implemant the provisions of GL 89/01.
Due
's nature of these changes, they cannot create the possi.
i/ of a new or different kind of accident.
The addition of new definitions to the technict.1 specifications is an enhancement to present provisions.
STS guidelines are used for the new definitions and have been evaluated and found to be in agreement with present usage at Quad Cities.
New Tables 1-1 and 1-2 follow an ST3 format for implementing present Quad Cities Surveillance Frognencies and Operational Modes.
Present Operational Mode rest'
'ons on reactor coolant tcmperature are retained for m al Modes 1,
2, 3,
and 4; and, are changed to GTS guidel....
Operational Mode 5
' resent reactor modo switch ps stion restrictions are
.ned by including necessary notes to allow testing a'
.ar operations.
Since either present provisions are
.ned or present interpretation of reqairements'are aaintained, the changes do not create the possibility of a new or different kind of accident from any previously evaluated.
3)
Involve a significant reduction in the margin of safety because:
The proposed changes to the definitions provide clarifications, implement proven changes from operating DWRs that are applicable at Quad Cities, and include present provisions and interpretations presented in STS format.
Present margins of safety are retained and improved by clarifying requirements that are subject to interpretation or are not presented in an easy to understand format.
The proposed change to the Core Alteration definition does not affect nuclear safety since replacement of incore instrumentation under the vessel has little or no measurable impact on core reactivity.
The change from the " Instrument" to the " Channel" philosophy for calibration, checks, and functional tests provides clarification of present intent.
Clarifications to the definitions for Primary and Secondary Containment Integrity are made to prevent misinterpretation of intent of the present requirements and do not reduce any margin of safety.
The proposed revision to the definition of
Critical Power Ratio will meroly redofine, in broader terms,.
the definition of critical power ratio and will not causo a change in any margin of safety.
Each fuel roload analysos will continue to ensure that the fuel system design, nuclear design, thermal / hydraulic design and the conclusions of the original core analysis remain valid for the accidents and limiting transients previously evaluated in the SAR.
The changes to the definitions for Fraction of Rated Power and Minimum Critical Power Ratio are clarifications of present requirements that do not changt present technical intent.
The changes to the definitions for PJP and ODCM more c1carly.
dofine the contents of these documents with the implementation of GL 89/01 provisions.
As such these changes cannot reduce any margin of safety.
The now defjnitions added to Section 1.0 apply to terms in current use in the Quad cities Technical Specifications and this addition improves understanding of requiren.onts.
Now Tables 1-1 and 1-2 follow the STS in format with notations and operational modes based on present Quad cition Technical Specification requirements, interpretation of requirements, or STS guidelince that are applicable to Quad Cities.
Tablo 1 -2 notes follow present Quad cities allowancos or interpretation of allowances and. follow later operating plants and STS guidelines.
Since the proposed changes implement present Quad Cities allowances in an STS format and follow proven allowances at other operating plants that are acceptable for use at Quad Citics, there is no reduction in any margin of safoty.
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' t EMYIAQHREHIAL ABIEREMIMI KYAkUAT10H-PROPOSED SPECIFICATION SECTION 1.0 DEFINITIONS Commonwealth Edison has evaluated the pror,oned amendment in accGrdance with the requirements of 10 CFR Bl.21 and has determined that the amendment meets the requirements for categorical exclusion as specified by 10 CFR 51.22(c) (9).
- Commonwealth Edison has determined that the-amendment involves no significant hazards consideration, there are no significant-change in the types or significant increase in the amounts of any effluent that may be released offsite,~and there is no signi'ficant increase in individual or cumulative occupational radiation exposure.
- The proposed amendment does not modify the existing facility and does not involve any new operation of the plant.
As such, the proposed amendment does not. involve any change in the-type or.significant increases in effluents, or increase individual or cumulative occupational radiation exposure.
The proposed amendment to Section 1.0,
" Definitions" contain-administrative changes.such as arranging the definitions in alphabetical order and assigning numerical designation.- The proposed amendment updates the existing definitions to be consistent with current industry standards and adds new definitions which are provided in the Standard = Technical Specificetions and later operating plants' Technical Specifications.
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