ML20082H718

Application for Amends to Licenses DPR-29 & DPR-30,revising SR for HPCI & RCIC Sys

ML20082H718
Person / Time
Site:	Quad Cities
Issue date:	04/10/1995
From:	Schrage J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20082H722	List: ML20082H718 ML20082H748
References
NUDOCS 9504170327
Download: ML20082H718 (5)

Text

Commonwealth l~dmn Company I HM) Opus ihre

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April 10,1995 l l U.S. Nuclear Regulatory Commission  ;

Washington, D.C. 20555 l l

Attn: Document Control Desk l l

Subject:

Quad Cities Station Units 1 and 2 Application for Amendment to Facility Operating

Licenses DPR-29 and DPR 30 Appendix A, Technical Specifications '

Revision of High Pressure Coolant Injection and .

Reactor Core Isolation Cooling Surveillance Requirements NRC Docket Nos. 50-254 and 50-265 i

i In accordance with 10 CFR 50.90, Commonwealth Edison (Comed) proposes to amend Appendix l A, Technical Specifications, of Facility Operating Licenses DPR 29 and DPR-30. : The proposed License Amendment would revise Surveillance Requirements for the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) systems.

The proposed changes revise the wording of the HPCI and RCIC flow rate test surveillances to be l

more consistent with the format and nomenclature of the BWR Standardized Technical Specifications (NUREG 0123 and NUREG 1433). This change will revise the current pressure requirements for pump testing and eliminate unnecessary challenges to equipment. The proposed change also revises the low pressure value at which the HPCI and RCIC systems are tested following a refuel outage or an outage in which work was performed which directly affected system operability. The current low pressure Technical Specification value for the flow rate test is not consistent with the operability requirements of the systems.

The amendment request is subdivided as follows:

1. Attachment A provides a description and safety analysis of the proposed changes to the Technical Specifications.

l 2. Attachment B provides marked-up (Unit 1) and retyped (Unit 2) Technical Specification pages.

3. Attachment C describes Comed's evaluation performed in accordance with 10CFR50.92(c), which confirms that no significant hazards consideration is involved.

4. Attachment D provides the Environmental Assessment.

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l This proposed amendment has been reviewed and approved by both Comed On-Site and Off-Site Review in accordance with Commonwealth Edison procedures. ,

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

l Commonwealth Edison requests review and approval of this proposed License Amendment by Jtme l 1,1995, to support testing of the systems under the new requirements during startup following the l

j' current Quad Cities Unit 2 refuel outage.

To the best of my knowledge and belief, the statements contained above are true and correct. In some respects, these statements are not based on my personnel knowledge, but upon information furnished by other Commonwealth Edison and contractor employees. Such information has been l reviewed in secordance with company practice, and I believe it to be reliable.

Please direct any questions you may have concerning this amendment request to this office.

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,b OFFICIAL SEAL  !! Respectfully, MARY JO YACK  :

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Attachments:

l A. Description and Safety Evaluation of the Proposed Changes B. Marked-up (Unit 1) and retyped (Unit 2) Technical Specification Pages C. Evaluation of Significant Hazards Consideration D. Environmental Assessment l

ec: J.B. Martin, Regional Administrator - Rill

C. Miller, Senior Resident Inspector - QCNPS '

( R.M. Pulsifer, Project Manager NRR Office of Nuclear Safety - TDNS kAnla\ quad \techspec\hprchr).wpf

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, ATTACHMENT A  ;

i DESCRIPTION AND SAFETY ANALYSIS OF THE PROPOSED CHANGES A. DESCRIPTION OF THE PROPOSED CHANGE I The proposed License Amendment revises the Surveillance Requirements for the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) systems. The proposed l changes revise the wording of the HPCI and RCIC flow rate test surveillances to be more  !

consistent with the format and nomenclature of the BWR Standardized Technical Specifications (NUREG 0123 and NUREG 1433). This will revise the current pressure requirements for ,

pump testing, eliminating unnecessary challenges to equipment.

The proposed changes also revise the low pressure value at which the HPCI and RCIC systems are tested following a refuel outage or an outage in which work was performed which directly affected system operability. The current low pressure value for the flow rate test is not consistent with the operability requirements of the systems. The proposed change allows low pressure flow rate testing of HPCI and RCIC at a pressure equal to the reactor vessel pressure at which the systems are required operable.

The proposed changes also revise the applicable section of the Technical Specification Bases to incorporate the revised testing requirements.

B. DESCRIPTION AND BASIS OF THE CURRENT REQUIREMENT The Quad Cities Station Unit 1 and Unit 2 Technical Specifications (TS) currently require the following flow rate tests for the HPCI (TS 4.5.C.3) and RCIC (TS 4.5 E.3) systems:

A quanerly flow rate test to demonstrate design flow against a system head corresponding to reactor vessel pressure of greater than or equal to 1150 psig when steam is supplied to the turbine at 920 to 1005 psig; and, A low pressure and high pressure flow rate test during startup following a refuel outage or an outage in which work was performed which directly affected system operability.

These tests demonstrate design flow against a system head corresponding to reactor vessel pressure of greater than or equal to 300 psig (low pressure test) and 1150 psig (high pressure test) when steam is supplied to the turbine at 250 to 325 psig (low pressure test) and 920 to 1005 psig (high pressure test).

The quarterly flow rate test demonstrates pump operability by meeting ECCS design flow requirements when steam is supplied to the turbine at rated reactor vessel pressure. This test requirement also satisfies the testing provisions of the Inservice Testing Program.

The combination of low and high pressure flow rate tests following a refuel outage or an outage in which work was performed which directly affected system operability provide adequate assurance of pump performance throughout the range of reactor pressure at which the systems are required to operate. The dual pressure flow test requirements were added to the Quad Cities Unit 1 and Unit 2 Technical Specifications by Amendments 130 and 124. j kAnt4\ quad \teclupeewpcirei4.wpf l

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, Page 2 The low pressure test, which was added to the current Technical Specifications by Amendments 130 and 124, was designed to demonstrate HPCI and RCIC design flow and system performance prior to continuing power ascension during a reactor startup.

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l C. DESCRIPTION OF THE NFFD FOR THE TECHNICAL SPECIFICATION l l AMENDMENT l l The BWR Standardized Technical Specifications (NUREG 0123 and NUREG 1433) and the j TSs for more recently licensed BWRs require the performance of the quarterly flow rate test and post-refuel outage high pressure flow rate test against a system head corresponding to reactor pressure. The current Technical Specifications require this system head to be greater than or equal to 1150 psig. This value is greater than the rated reactor pressure of 1000 psig.

l Comed has identified that this testing at a significantly higher pressure has been associated with l accelerated wear and challenge to HPCI and RCIC mechanical components during testing. ,

l The BWR Standardized Technical Specifications (NUREG 0123 and NUREG 1433) and the l TSs for more recently licensed BWRs require the performance of the post-refuel outage low l pressure flow rate test near a pressure equal to the point at which HPCI and RCIC are ,

l required to be operable (i.e. the point at which adequate pressure is available to perform the j test). Current TS 3.5.C.1 and 3.5.E.1 require HPCI and RCIC to be operable when reactor  !

pressure is greater than 150 psig. The current specifications require testing between 250 psig l and)325 psig reactor pressure. Comed has identified that this is a non-conservative difference  ;

between the BWR-STS requirement and the current Quad Cities Unit 1 and Unit 2 Technical i Specifications.

D. DESCRIPTION OF THE AMENDED TECHNICAL SPECIFICATION l'

The proposed changes revise the wording of the HPCI and RCIC quarterly flow rate tests, and the post-refuel outage How rate tests to require the performance of the flow rate tests against a system head corresponding to reactor pressure. The proposed change will require that the HPCI and RCIC systems deliver a flow rate of 5000 gpm and 400 gpm respectively, when tested against a system head corresponding to reactor vessel pressure, when steam is supplied to the turbine at 920 psig to 1005 psig (quarterly flow rate test and post refuel outage high pressure test) and 150 psig to 325 psig (post-refuel outage low pressure test).

l The proposed changes also revise the pressure at which the HPCI and RCIC post refuel outage low pressure flow rate test is performed to be consistent with the pressure at which HPCI and RCIC are required to be operable. The proposed change will require that the HPCI and RCIC l systems deliver a flow rate 5000 gpm and 400 gpm respectively, when tested against a sys+em l head corresponding to the reactor vessel pressure and steam is supplied to the turbine at 150 psig to 325 psig.

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The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit to perform the post-refuel outage flow rate tests, once the required

! reactor vessel pressure is reached, is retained from current Technical Specifications. This is consistent with BWR STS requirements.

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! The proposed changes also revise the applicable section of the Technical Specification Bases to incorporate the revised testing requirements. .

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l E. BASES FOR THE PROPOSED TECHNICAL SPECIFICATION AMENDMENT ,

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l The proposed changes to the Quad Cities Station Unit 1 and Unit 2 Technical Specifications )

l will revise the HPCI and RCIC quarterly and post-refuel outage flow rate test requirements to j eliminate unnecessary strain on the systems, and will lower the pressure at which testing L commences to a reactor pressure consistent with the pressure at which the systems are required l to be operable.

These proposed changes are more conservative than the current requirements, and are consistent with BWR Standardized Technical Specifications (NUREG 0123 and NUREG 1433) j j and the TSs of more recently licensed BWRs. l l Given that the proposed changes are more conservative than the current requirements, and consistent with the BWR-STS, Comed finds this proposed Technical Specification Amendment

acceptable.

F. SCHFDULE

! Comed requests approval of this proposed amendment by June 1,1995, with an implementation date corresponding to the completion of the Unit 2 thirteenth refuel outage, currently scheduled for June 8,1995.

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