Text

Application for Amends to Licenses DPR-29 & DPR-30,App a, Reflecting Efforts to Upgrade Existing Tech Specs 3.3/4.3, Reactivity Control
	ML20082V202
Person / Time
Site:	Quad Cities
Issue date:	09/17/1991
From:	Stols R; COMMONWEALTH EDISON CO.
To:	Murley T; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20082V205	List: ML20082V202; ML20082V212;
References
	NUDOCS 9109230159
	Download: ML20082V202 (33)
	v • d • e

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[* *N C mmonw:alth Edistn l

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) 1400 Opus Place

! ~)' Downers Grove, tilinois 60515 O '

N September 17,1991 l

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

Subject:

Quad Cities Nuclear Power Station Units 1 and 2 Application for Amendment to Facility Operating Licenses DPR 29 and DPR-30, Appendix A, Technical Specifications Technical Specification Upgrado Program JBORocketMosm50454 and 50MS Dr. Murley:

1: 4 990, Quad Cities Station initiated a formal prc gram to enhance the Station's performance ei various aspects of plant operation. The Performance Enhancement Program (PEP) was developed by assessing existing improvement plans, identifying potential weaknesses and prloritizing improvement actions. Necessary improvements to ths Technical Specifications were identified 8.s one of the Station top priority issue. Details of the goal and methodology for the Technical Sp*ec;fication Upgrade Program are provided in the Executive Summary section of the proposer amendment. The Program has been previously discussed with members of the NRR staff.

Pursuant ta 10 '.,FR 50.90, Commonwea!th Edison proposes to amend Appendix A, Technical Specifications '.o Facility Operating Licenses DPR-29 and DPR 30. The proposed amondment reflects Commonwealth Edison's efforts tr upgrade existing Technical Specification Section 3.3/4.3, " Reactivity Control". An overall description of the proposed amendment is also included in the Executive Summary.

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

1, An Executive Summary of the Technical Specification Upgrade rmgram and th^

proposed amendment; 2.

A summary of the changes; 3.

. detailed description of the changer; 4.

The proposed Techn! cal Specification pages w.th the requested changes; 5.

The existing Technical Specification pages for DPR-29, are marked-up to reflect the appropriate changes to the existing bases sections.

6.

Commonwealth Edison'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 Tecnnical Specifications.

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Dr. Thomas E. Murley September 17,1991 The proposed amendment has beon reviewed and approved by Commonwealth Edison's on-site and off-sito review in accordance with Company procedures.

The Technical Specification Upgrade Program proposes changes to each section of the existing Technical Specifications. As such, Commonweafth Edison requests that the proposed amendments be approved and issued as one document rather than as individual sections. All proposed changes to the Technical Specifications which are developed under this program will be submitted to the Commission by no later than September 30,1991.

Commonwealth Edison respectfully requests the NRC's approva! of the upgraded Tachnical Specifications by July 1,1992.

To the best of my knowled e and belief, the statements conta'ned are true and 0

correct. In some respects, these statements are not based on my personal knowledge but obtained information furnished by other Commonwealth Edison employees and consultants.

Such information has been reviewed in accordance with Company practice and I believe !! 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 conceming this proposed amendment to R. Stols at 708/515-7283.

/

Very tr ly yoursa pl

[bl#f L

G,y Rita StoI' Nuclear icensing Administrator Enclosure (A):

Proposed Amendment to Technical Specification Section 3.3/4.')

" Reactivity Control" cc:

A.Bert Davis, Regional Administrator - Rlli L.N. Olshan, Pro,ect Manager - NRR T.E. Taylor, Senior Resident inspector - OC i

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b QUAD CITIES NUCLEAR POWER STATION TECHNICAL SPECIFICATION UPGRADE PROGRAM PROPOSED AMENDMENT I

SECTION 3.3/4.3 " Reactivity Control" l

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. EXECUTIVE

SUMMARY

I Proposed' Changes to TS 3.3/4.3

' REACTIVITY CONTROL' I

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-EXECUTIVE REKKARY QUAD CITIES TECHNICAL SPECIFICATION UPGRADE PROGRAM The Quad Cities Technical Specification Upgrade Program was conceptualized in response to lessons learned from the Dresden Diagnostic Evaluation Team inspection and the frequent need for Technical Specification interpretations.

A comparison of the existing Quad Cities Technical Specification and, Standard Technical Specifications and later operating plants' Technical Specification provisions W&2 conducted to ider.tify 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 Citier custom Technical Specifications provide for safe operation of the plant and, therefore, only a upgrade was deemed appropriate.

The comparison study revealed a mix of recommended upgrades which included the relaxation of certain existing Technical Specification requirements, the addition of surveillances, the removal of allowances which would no longer be allowed under new plant licensing, and better definition of appropriate action requirements in the event a Limiting Condition for Operation cannot be met.

The Technical Specification Upgrade Program also implemtnts NRC recommended line item improvements to the Technical Specifications which were issued under Generic Letters.

In response to an NRC recommendation, the Unit 1 and Unit 2 Technical Specifications are combined into one document.

To accomplish the combination of the Units' Technical Specifications, a comparison of the Unit 1 and Unit 2 Technical Specifications was performed to identify any technical differences.

The technical differences are identified in the proposed amendment package for each section.

~The Technical 3pecification Upgrade Program was identified as a Station Top Priority during the development of the Quad Cities Station's Performance Enhancement Program (PEP). The Technical Specification Upgrade Program's goal is to provide a better tocl to Station personnel to implement their responsibilities and to ensure Quad Cities Station is operated in accordance with current industry practices.

The upgraded specifications provide for more safe and reliable operation of the plant, The program improves the operator's ability to use the Technical Specifications by more clearly defining Limiting Conditions for Operations and required actions.

c EXEEETlYE_

SUMMARY

(Continued)

Proposed Changes to Technical Specification Section 3.3/4.3, " Reactivity Control" The proposed change deletes the present Objective statement and provides Applicability statements within each specification similar to the STS.

The proposed Applicabilitv statement includes the Reactor Modes or other conditions for whicb the LCO 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 from the present location of immediately following the LCO material to the end of the section.

For sections with tables or figures, the tables and figures will now be located after the LCos and before the bases.

The specifications in Section 3.3/4.3 have been reordered and new titles have been added based on STS arrangements and nomenclature.

Present Specification 3.3.A, Reactivity Limitations, is retitled as Shutdown Margin in accordance with STS guidelines.

Action statements are proposed based on STS guidelines.

Additional surveillance for Section 4.3.A implements STS and later operating l

BWR plant provisions for checking Shutdown margin when withdrawn control rods are inoperable due to being immovable.

Proposed Specification 3.3.B/4.3.D, Reactivity Anomalies, replaces present Specification 3.3.E/4.3.E.

The proposed Action statements follow STS guidelines.

L The proposed LCO for Specification 3.3.C, control Rod operability, is taken from a combination of present provisions and STS guidelines.

The present provision which allows control rods that are fully inserted and disarmed to not be considered inoperable, is deleted.

The proposed Applicability and Action statements implement STS guidelines and replace present requirements.

Proposed Surveillance Requirement 4.3.C retains present provisions to exercise control rods weekly and daily while using STS wording to implement the requirements.

In accordance with STS guidelines, three new sections:

3.3.D/4.3.D, Control Rod Maximum Scram Insertion Times; 3.3.E/4.3.E, Control Rod Average Scram Insertion Times; and, 3.3.F/4.3.F, Four Control Red Group Scram Insertion Times, are proposed as replacements for present Specification 3.3.C/4.3.C on Faram Insertion Times.

Proposed Specification 3.3.G/*.3.G, Control Ro2 Scram Accumulators, is a rewrite of present Specification 3.3.D/4.3.D.

The proposed Actions for inoperable control rod scram accumulators implement STS guidelines.

The oroposed Surveillance Requirements incorporate the weekly STS testlng guidelines.

Proposed Specification 3.3.H/4.3.H, Control Rod Drive Coupling, is

i a rewrite of existing Specification 3.3.B.1/4.3.B.l.

Proposed Action steps for uncoupled control rods follow STS guidelines.

Present Surveillance Requirements 4.3.D.1 are changed to match STS guidelines and format.

Proposed Specification 3.3.I/4.3.I is a rewrite of existing specification 3.3.A.3/4.3.A.3 on the Control Rod Position Indication System with proposed Actions and Surveillance Requirements being based on STS guidelines and provisions from later operating BWR plants.

Proposed Specification 3.3.J/4.3.J, Control Rod Drive Housing Supports, is a rewrite of existing Specification 3.3.B.3/4.3.B.2.

The proposed LCO and Applicability follow STS guidelines ar.d implement present technical specification provisions.

The proposed Action follows STS guidelines.

The present surveillance requirement is rewritten using STS wording.

Proposed Specification 3.3.K/4.3.K, Scram Discharge Volume Vent and Drain Valves, is a rewrite of present Specification 3.3.B.6/4.3.B.6, which addresses only the Surveillance Requirements and does not contain LCO, Applicability or Action provisions.

The rewrite uses NRC accept.ad previsions at other operating BWRs to address the missing requirements.

Proposed Specification 3.3.L/4.3.L, Rod Worth Minimizer, is a rewrite of present Specification 3.3.E.3.b/4.3.B.3.

The proposed LCO and Applicability statements are taken from present provisions and arranged in an STS format.

Proposed Action steps for an inoperable RWM are taken from JTS guidelines.

Proposed surveillance requirements are taken from present testing provisions and STS guidelines.

Proposed Specification 3.3.M/4.3.M, Rod Block Monitor, is a rewrite of present Specification 3.3.B.5/4.3.B.5.

The proposed LCO implements present requirements and the Action steps are based on STS guidelines.

The proposed Surveillance Requirements are taken from present technical specification requirements which coincide with STS guidelines.

Proposed Specification 3.3.N/4.3.N, Source Range Monitoring Function, follows STS guidelines-Proposed Specification 3.3.0/4.3.0 on the Economic Generation Control System retains the present provisions of Specification 3.3.F/4.3.F.

STS format and wording style are used for consistency with other proposed changes.

The proposed changes to the 3.3/4.3 Bases are made io support the changes proposed to the individual specifications.

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SUMMARY

-OF CHANGES

- l PROPOSED TS 3,3/4,3

' REACTIVITY : CONTROL" m

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SUMMARY

QZ CEANGES Proposed Specification 3.3/4.3 Reactivity Control

!This section contains proposed changes to Quad Cities-Units 1 and 2 Technical-Specification Section 3.3 4.3.

Some of the changes proposed are made-to improve readabil ty and usability of the present; technical' specifications by. incorporating a format similar

-to the Standardt Technical Specifications.

Other changes provide technical-improvements by incorporating provisions from other operating BWRs.and/or the Standard Technical Specifications (STS).

-_The specific-changes are described-below.

Item 1:

Pace-3.3/4.3-1. DPR-29

't a.

Delete the present Applicability and Objective sections at the beginning of Section 3.3/4'.3.

The Applicability statement is

.being. included after the Limiting Conditions for Operation in each individual specification.

o Item.2:-

b Pace 1 314.3-1.. Specification-3.1.A.1/4.3.&zlu DPR-29 a.

PresentfSpecification 3.3.A.1/4.3.A.1 on Reactivity-margin--

core loading is changed __to 3.3.A/4.3.A and titled " Shutdown t

! Margin".1 b.

'Present LCO requirements art changed by adding the present-Surveillance Requirement of-.25%~ delta k/k as-the limit.

The Applicability section is added to reflect present requirements

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of all Operational Modes (1, 2,

3, 4, and?5).

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'c.- Action" statements-are added similar'to,STS provisions. _ With L

the Shutdown Margin not met.in Operational Modes 1 or 2, the-

' Shutdown Margin:must be restored within-6-hours or the reactor must be in at least-Hot Shutdown within the next-12 hours With the Shutdown Margin not met in Operational Modes 3,i [esor 5,; action must be taken:to=immediately suspend all activ that could reduce the Shutdown Margin, insert or-verify

inserted allninsertable control rous, and establish. secondary.

-containment integrity.

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Proposed Surveillance _ Requirement 14.3.A.1.a isstaken from L

present-requirements of Surveillance Reguirement 4.3.1 and crequires Shutdown Margin measurement prior: to cnc during the L

first startup after each refueling outage whure core

. alterations were performed.

Proposed Surveillance Requirement

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4.3.A.1.b is taken from provisions of present-Specification 3.3.A.2 for' inoperable control-rods and STS provisions.

SR L

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e 4.3.A.l.h requires the Shutdown Margin to be determined within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after detection of a withdrawn control rod that is immovable, as a result of excessive friction or mechanical interference, or is untrippable, except that the required Shutdown Margin shall be verified acceptable with an increased allowance for the withdrawn worth of the immovable or untrippable control rod.

Item 3:

Engaa 3.3/4.3-1. 3.3/4.3-2. Specification 3.3.A.2/4.3.A.2m DEE:12 a.

Present Specification 3.3.A.2/4.3.A.2, Reactivity Margin -

Inoperable Control Rods, is rewritten as Specification 3.3.C/4.3.C titled " Control Rod Operability".

b.

Proposed LCO for Specification 3.3.C is based on present provisions and STS guidelines for all control rods to be operable The present provision that control rod drives which are fully inserted and disarmed shall not be considered inoperable, is deleted, c.

Applicability is added as Operational Modes 1 and 2.

These operability requirements match current provisions in Specification 3.3.A.2.e of during reactor power operation.

d.

Proposed Actions for Control Rod Operability are taken from STS guidelines.

Proposed Action 3.3.C.1 addresses the condition with one control rcd inoperable due to being immovable, as a result of excessive !riction or mechanical interference, or known to be untrippable.

Proposed Action 3.3.C.2 addresses the condition where one or more control rods are trippable but inoperable for causes other than addressed in Action 3.3.C.l.

Proposed Action 3.3.C.3 requires with Kore than a control rods inoperable, the. reactor be in at least riot Shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The proposed Actions allow control rod directional control valves to be disarmed either electrically or hydraulically.

Present provisions allow only electrical disarming of the valves.

An exception to the provisions of Specification 3.0.D is added to Action 3.3.C.2.

e.

Proposed Surveillance Requirement 4.3.C is based on present requirements to exercice each partially or fully withdrawn rod at least one notch at least once por week.

The present 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months surveillance is replaced with the STS provision and the

. reference to collet housing failure is deleted.

Proposed SR I

4.3.C.2 references SR 4.3.D,-4.3.G, 4.3.H and 4.3.I to demonstrate control rod operability.

Item 4:

Pace 3.3/4.3-3. Soccification 3.3.A.3/4 1.A 3, DPR-29 a.

Present Specification 3.3.A.3/4.3.A.3 is rewritten as proposed 1

Spccification 3.3.I/4.3.I titled " Control Rod Position Indication System",

b.

The proposed LCO is taken from STS requirements and requires all control rod position indicators to be operable, c.

The proposed Applicability based on STS guidelines is Operational Modes 1, 2,

and 5 with the applicability in Operational Mode 5 for withdrawn control rods and not for rods removed per Specifications 3.10.D or 3.10.E.

d.

The proposed Actions for an inoperable control rod position indicator are based on STS guidelines.

The Actions for Operational Modes 1 or 2 requires that within orr hour, the position of the control rod be determined by an c1 ternate method or the control rod be moved to a position with an oparable position indicator, or the centrol rod is declared inoperable, inserted and disarmed.

The Actions for an inoperable posit;en indicator in Operational Mode 5 require moving the control rod to a position with an operable position indicator or inserting the control rod.

An exception is added from later operating BWR plants to allow disarmed directional control valves to be rearmed intermittently, under administrative control, to permit testing associated with re storing the control rod (s) to operable status.

An exception to the provisions of Specificaticn 3.0.D is added per STS guidelines.

e.

Proposed Surveillance Requirements 4.3.I for the control rod position indicators are taken from present requirements and STS provisions.

The proposed surveillances check the pcaition indicators at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , during movement of the CRD while performing SR 4.3.C.1, and the full out irdicator while performing SR 4.3.H.2.

Present provisions of SR 4.3.A.3.b are deleted since acoption of STS guidelines for Action requirements do not include scramming the control rod (s) that have an inoperable position indication.

Item 5:

Paces 3.3/4.3-3 and 3.3/4.3-4. Egecifications 3.3.B.1/4.3.B.1 and 12 3..B 22 DPR-29 a.

Present Specifications 3.3.B.1/4.3.B.? and 3.3.B.2 are rewritten as Specification 3.3.H/4.3.H titled " Control Rod Drive coupling".

b.

The proposed LCO is taken from present provisions and requires all control rods to be coupled to their drive mechanisms during applicable modes.

c.

The proposed Applicable Modes are Operational Modes 1, 2,

and 5 with the applicability in Operational Mode 5 for withdrawn control rods and not for control rods removed per o __ _____ _ _ _ __

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Specification 3.10.D or 3.10.E.

These provisions are based on STS guidelines.

d.

The proposed Actions are taken from STS guidelines and allow an attempt at recoupling before inserting and disarming the affected control rod.

An exception is added from later operating BWR plants to allow disarmed directional control valves to be rearmed intermittently, under administrative control, to permit testing associated with restoring the control rod (s) to operable status.

An exception to the provisions of Specification 3.0.D is added to Action 3.3.H.1 in accordance with STS guidelines.

The present Surveillance Requirements are rewritten using an e.

STS format while maintaining the intent of'the present prov isionr..

Item 6:

Paqo 3.3/4.3-4. S,pecification 3.3.B.3/4.3.B.1 Contrgl End Drive

!!ousina Supoort. DPR-29 a.

Present Specification 3.3.D.3/4.3.B.2 is rewritten using STS guidelines as Specification 3.3.J/4.3.J titled " Control Rod Drive Housing Support".

b.

The proposed LCO requires all control rod drive housing supports to be in place during applicable Operational Modes.

c.

Applicable Operational Modes include 1, 2,

and 3 similar to present provisions of during reactor power operation and when the reactor coolant system is pressurized above atmospheric

pressure, d.

Present Specification requirements do not contain Action provisions.

Action provisions are added such that with the control rod drive housing not in place, the reactor shall be in at least Hot Shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in at least Cold Shutdawn within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , c.

Present Surveillance Requirament 4.3.B.2 is rewritten using STS guidelines such that inupections are performed after disassembly or maintenance has been performed in the housing support area.

Item 7:

Paces M /4. 3-4 gDd 3. 3/4,J-L Sng _gifications 3. 3. B. 3. a.

3.3.B.1.b and 4.3.B.3.

Egg Worth Minimizer. DPR-29 a.

Present Specification 3.3.B.3.a contains a description of how to establish control rod sequences.

This description is deleted since an adequate discussion presently exists in 3ases 3.3.

b.

present Specifications 3.3.B.3.b and 4.3.B.3 are rewritten as Specification 3.3.L/4.3.L and titled " Rod Worth Minimizer".

c.

The proposed LCO for the RWM requires the RWM to be operable in the applicable modes and is taken from STS guidelines, d.

The proposed Applicability is taken from present requirements and requires the RWM to be operable in Operational Modes 1 and 2 when thermal power is less than 20% of Rated Thermal Power.

The RWM may be bypassed for low power physics testing to demonstrate the shutdown margin requirements of Specification 3.3.A if a technically qualified individual is present and verifies the step-by-step rod movements of the test procedure.

An exception is added to allow entry into operational Mode 2 to determino RWM operability prior to taking the reactor

critical, e.

The proposed Actions with an inoperable RWM are taken from present provisions and STS guidelines.

The present provision of using a second licensed operator or technically qualifted engineer who it present at the reactor control consolo to verify control 1 d movement and complience with the prescribed control rod pattern is retained except that the qualified

" engineer" is changed to qualified " individual." The present provision of requiring at least 12 control rods to be withdrawn to the fully withdrawn position before allowing the use of a second licensed operator or other technically qualified engineer to substitute for the RWM is deleted.

An STS guideline is added to the Actiens such that without use of the second licensed-operator or technically qualified individual, control rod movement r.ay be only by actuating the manual scram or placing the reactor mode sw tch in the Shutdown position.

f.

The propose' lurveillance Requirements for the RWM incorporate present ref '.rements and utilize STS guidelines.

Operational Mode 1 and i testing involves verifying proper indication of the selection error of at least one out-of-sequence control rod and demonstrating inability to withdraw an out-of-sequence y

cor. trol rod.

Proper checks of the control rod patterns and sequence inputs are required following any loading of the program into the computer.

Item 8:

Pace 3.3/4.3-5 Spagitication 3.3.B.4/4.3.B.4. SJ;Lqtqn Rance 2

Monitorina, DPR-29 a.

Present Specification 3.3.B.4/4.3.B.4 is rewritten as Specification 3.3.N/4.3.N using STS guidelines and titled

" Source Range Monitoring Function".

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b.

The present provision requiring at least two SRMs operable in Operational Modes 2, 3,

and 4, is expanded to incorporate STS guidelines requiring three SRMs operable in Operational Mode 2.

The proposed Applicability is taken from STS guidelines and c.

requires operability in operational Modes 2, 3,

and 4 with operability in Operational Mode 2 required only with IRMs on range 2 or below.

The present requirement for operability for control rod withdrawal during refueling is moved to Section 3.10/4.10.

d.

The Proposed Actions for inoperable SRMs are taken from STS guidelines.

In Operational Mode 2 with one of the required SRMs inoperable, the proposed Action re@ ires restoration of at least 3 SRMs to operable status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or the reactor be in at least Hot Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

In Operational Modes 3 or 4 with one or more of the required SRMs inoperable,-the proposed Action is to verify all insertable control rods are inserted in the core and to lock the reactor mode switch in the shutdown position within one hour.

i c.

The present Surveillance Requirement, to verify SRM count rate of at least 3 cps with the detector fully inserted prior to withdrawal of control rods, is retained.

Added from the STS are Surveillance Requirements to perform Channel Checks, Channel Calibrations, and Channel Functional Tests.

Item 9:

Pace 3.3/4.3-5. SnecificatioD 3.3.B.5/4.,3.B.5. Bgd Block Monitor.

DPR-29 a.

Present Specification 3.3.B.5/4.3.B.5 is rev;ritten as Specification 3.3.M/4.3.M and titled " Red Block Monitor".

b.

The proposed LCO cones from present requitenonts and requires both RBM channels to be operable.

The proposed Applicability in based on present requirements in c.

Note 1 of T4tle 3.2-3 and STS guidelines, The RBM channels are required Uperable in Operational Mode'1, when thermal power is greater than or euual to 30% of rated thermal power.

One channol may be bypassad above 30% rated thermal power without a time restriction provided that a limiting control rod pattern does not exist and the remaining RBM channel is operable.

Both RB'l channels are automatically bypassed when a peripheral rod is selected, d.

The proposed Actions for inoperable RBM channels are taken from present requirements and STS guidelines.

The proposed Action with one RBM channel inoperable and not bypassed

requires verification that a limiting control rod pattern does not exist and restoration of the channel within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; otherwise, the inoperable RBM channel is placed in the tripped conditien within one hour.

The proposed Action with both RBM channels inoperable requires placing at least one channel in the tripped condition within one hour, The proposed Surveillance Requirements reference Table 4.2-1 e.

for required testing and retains present intent to perform a channel functional test prior to control rod withdrawal when the reactor is operating in a limiting control rod pattern and daily thereafter.

Item 10:

Pagna 3. 3 / 4,. )-jli and 3. 3 / 4. 3-6. SnecificatLQD 4.3.B.6.

EgrJug pincharon Volume y_qnt and DralD Valves. DPR-29 The present Specification for the Scram Disenarge Volume Vent a.

and Drain Valves contains only Surveillance Requirements.

The proposed change adds LCO, Applicability and Action provisions as Specification 3.3.K/4.3.K, modeled after later operating BWR plants, b.

The proposed LCO requires all Scram Discharge Volume Vent and Drain Valves to be operable in the Applicable Modes.

c.

The proposed Applicability is Operational Modes 1 and 2.

d.

The proposed Actions require that with one scram discharge volume vent. valve inoperable and open, or one scram dischtige volume drain valve inoperable and open, or the combination of any one drain valvo and vont valve being inoperable and open, that the valve (s) be restored to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the plant be in at least llot Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

If any scram discharge volume vent valve (s) and/or drain valve (s) are inoperabla due to reasons other than those just described, the inoperable valves shall be restored to operable status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or the plant placed in at least llot Shutdown within the next 12

hours, c.

The present Surveillance Requirements are etainei for the Sci'am Discharge Volume Vent and Drain Valves.

Item 11:

Engra J.2 3/4 1-6 Specification J.3.C/4.3.C. Scram Insertion Times.and 3.3/4.3-7.

DPR-22 a.

Present Specification 3.3.C/4.3.C contains requirements for three specifications in the STS, the Control Rod Average Scram Insertion Times, the Four Control Rod Group Scram Insertion Tic.es and the Control Rod Maximum Scram Insertion Times.

The i

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i present Specification is proposed to be separated into

- 3.3.D/4.3.D for Control Rod Maximum Scram Ir.settion Times, 3.3.E/4.3.E for Control Rod Attrage Scram Insertion Times and Times /4.3.F for the Four Control Rod Group Scram Insertion 3.3.F

- b.

The present wording of Gpecification 3.3.C.2.for Control Rod Maximum Scram Insertion Times is retained for the LCO for propored Specification 3.3.D.

The proposed LCO requires the maximum scram insertion time for 90% of any operable control rod shal? not exceed 7 seconds.

The proposed Applicability is operational Moder 1 and 2 in accordance with STS guidelines.

The proposed Actions-follow STS guidelines end require declaring the control rod (s) inoperable and to perform SR 4.3.D.1.c at least once per 60 days when operating with three

-or more control rods exceeding the maximum scram insertion time.- If the-above SR is not met, then the reactor must bs in at least Hot Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

An exception to the provisions of Specification 3.0.D is added in accordance with STS guidelines.

Proposed Surveillance ERequirement 4.3.D.1 is taken from STS gui?elines and somo-present provisions.

SR 4.3.D 1 requires scram' time testing of all control rods prior to exceeding 30% of rated thermal power following core alterations or after a reactor shutdown that is longer than-120 days _ Specifically affected individual control rods are tested following maintenance on or modification to the control rod drive system that could affect the scram insertion times of:those specific control rods.

Also, at least 10% of the control rods, on a rotating basis, are scram time tested at least once per 120 days of reactor power operation.-- The-present requirement that all control rod-drivessexperience scram time measurements at least once Der d

. year and the requirement to scram time test 50% of tha control Orod drives in each quadrant of the core not more frequcntly than 16 weeks nor less frequently than 32 weeks are deleted.

-Present SR14.3.C.3 to determine the' cycle cumulative mean scram time-for 20% insertion is retained as SR 4.3.D 2.

c.

The.present' requirements of Specification 3.3.C.1 for Control Rod-Average Scram Insertion Times are retained as the-LCO for proposed Specification =3.3.E.

The proposed Applicability is operational Modes 1-and 2 in accordance with STS guidelines.

Proposed Action 3.3.E.1 follows the intent of present

-Specification 3.3.C.3 and requires that with the average scram insertion time exceeding any of the specified limits, the reactor be/in'at least Hot Shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

As above, the present requirement-of Specification 3.3.C.S to adjust the.MCPR operating limit if the overall average of the 20% insertion scram-time data exceeds the limit, is retained E'

as proposed Action-3.3.E.2.

Proposed Surveillance Requirements reference SR 4.3.D.

d.

The present requirement in Specification 3.3.C.1 for the Four Control Rod Group Scram Insertion Times-1s retained as the LCO g

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for prope. sed Specification 3.3.F.

The proposed Applicability is Operational Modes 1 and 2, based on STS provisions.

Proposed Action 3.3.F.1 follows STS guidelines and requires that with the scram time limits not met, the affected control rods are declared inoperable until analysis determines that appropriate scram reactivity remains and SR 4.3.D.1.c is performed at least once per 60 dayL with the everage scram insertion times exceeding the limits.

An exception to the provisions of Specification 3.0.D is added in accordance with STS guidelines.

Proposed Surveillance Requirement 4.3.F references SR 4.3.D.

Item 12:

Eagga 3.3/4.3-7 RDd 3.3/4.3-8 Specification 3.3.D/4.3.D. C2DtI21 t

- End Esrnm Accumulatom DPR-?.1 a.

Present Specification 7 3.D/4.3.D is rewritten as Specification 3.3.G/4.3.G and titled " Control Rod Scram 4

Accumulators".

b.

The proposed LCO for Specification 3.3.G is based on STS and present provisions.

All control rod scram accumulators are required operable in the applicable operational modes with the present exception + hat if the control rod is fully inserted and electrically disarmed, then the rod is not censidered to have an inoperable accumulator and associated rod blocks may be bypassed, c.

Proposed applicability is based on STS guidelines and requires operability of the control rod scram accumulators in Operational Modes 1, 2 and 5.

An exception la provided for Operational Mode 5 such that the Specification is applicable to control rods withdrawn and not to control rods removed per Specificatione 3.10.D or 3.10.E.

d.

Proposed Actions are based on STS provisivi

.rui replace present requirements determined en a nine-r; square array around the affected control rod.

Proposed Action 3.3.G.1 specifies steps to be taken when the plant is in Operational Mode 1 or 2.

With one control rod scram accumulator inoperable, within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months it must be restored to operable status or declared inoperable; otherwise, the plant must be in at least Hot Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

With more than one control rod scram accumulator inocerable and with any affected control rod withdrawn, one control rod drive pump must be verified to be operating or the reactor mode switch

-must bu placed in the Shutdown position.

Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months the inoperable control rods must be inserted and disarmed.

Proposed Action 3.3.G.2 specifies steps to be taken when the plant is in Operational Mode 5 and requires that when there is one withdrawn control rod with an inoperable accumulator, the control rod be inserted and disarmed.

With more than one withdrawn control rod with an associated inoperable l

accumulator or no control rod drive pump operating, the reactor mode switch is immediately placed in the Shutdown position.

An exception to the 3.0.D is added per STS guidelir, provisions of Specification es.

e.

Present Surveillance Requirement 4.3.D is replaced with STS guidelines.

Proposed SR 4.3.G added from STS guidelines, requires a verification at least once per 7 days that accumulator pressure is % 950 psig.

Item 13:

Pace 13 3/4.3-8. Specification 3.3.E/4.3.E. Reactivity Anomalies.

DPR-29 a.

Present Specification 3.3.E/4.3.E is rewritten as Specification 3.3.B/4.3.B, Reactivity Anomalies, b.

Present provisions cf Specification 3.3.E are used to form the proposed LCO for Specification 3.3.B.

The proposed LCO rc. quires the reactivity equivalent of the difference between the actual critical rod configuration and the expected configuration shall not exceed 1% delta k/k.

c.

The proposed Applicability of Operational Modes 1 and 2 follows STS and present requirements of during power operation.

d.

The proposed Actions are taken from STS guidelines which require that with the limit of 1% delta k/k exceeded, an l

analysis be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to determine and explain If explained and corrected,in at least Het l

the cause.

operation may continue; otherwise, the plant must be Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

e.

Present Surveillance Requirements 4.3.E are rewritten using STS guidelines and maintain present provisions to verify reactivity differences of less than or equal to 1% delta k/k during the first startup following core alterations and at L

least every equivalent full power month.

Item 14:

Page 3.3/4.3-8. Specification 3.3.Flf23.F, Economic Generation Control System. DPR-29 a.

Present Specification 3.3.F/4.3.F is rewritten as Specification 3.3.0/4.3.0, Economic Generation Control (EGC)

System, b.

Present provisions of Specification 3.3.F are used to form the LCO requirements offproposed Specification 3.3.0.

The proposed LCO allows operation of the unit with the EGC system with automatic flow control only in the range of 65% to 100%

of rated core flow with reactor power above 20%.

The proposed Applicability is taken from present provisions by c.

allowing operation of the EGC system in Operational Mode 1 with reactor power above 20%.

d.

The proposed Action with the plant operating in EGC outside of the limits, requires restoration to within limits within one hour or removal from EGC operation, Present Surveillance Requirement 4.3.F is retained as SR e.

4.3.0.

Item 15:

Eagfen 3 3/4.3-9 throuch 3.3/4.3_ % Limiting Conditions f_QI Qperation Bases ipI Snecification h DPR -29 The Bases for Specification 3.3 are rewritten to reflect the changes proposed to the individual Specifiestions.

')

DESCRIPTION OF CHANGES PROPOSED TS 3.3/4.3

' REACTIVITY CONTROL'

DESCRIPTION QZ PROPOSJQ MiE.Rp1RM REOUEST Proposed Specification 3.3/4.3 Reactivity Control The changes proposed in this amendment request are made to 1) improve the understanding and usability of the present technical 2

incorporate technical improvements, and 3) specifications, include some provi)sions from later operating BUR plants.

An item by item description of the proposed changes requested in provided below.

The Summary of Chenges 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 Objective statement and provide Applicability statements within each specification similar to the STS.

The proposed Applicability statement to be included in each specification will include the Reactor Operational Modes or other conditions for which the LCO must be satisfied.

Item 1 The proposed changes in Item 2 retain some of the present technical requirements fer the Reactivity Limitations technical specifications while adding appropriate Action, Applicability, and Surveillance Requirements from STS guidelines.

present Specification 3.3.A, Reactivity Limitutions, is retitled as Shutd)wn Margin in accordance with STS guidelines.

The proposed LCO for Specification 3.3.A is based on present re @ irements with wording changes to include the shutdown margin limitation of 0.25%

delta k/k currently stated in Surveillance Requirement (SR) 4.3.A.

This proposed change to the LCO appropriately places the limiting condition in the LCO instead of the SR.

The present applicability for the Shutdown Margin technical specifications is all Operational Modes.

The proposed change implements this requirement by requiring operability in Operational Modes 1, 2,

3, 4 and 5.

Present Specification 3.3.A nas no Action provisions and thus, Action statements are proposed based on STS guidelines.

Action 3.3.A.1 addresses Operational Modes 1 or 2 and requires restoration of the required Shutdown Margin within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months or be in at least Hot Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Action 3.3.A.2 addresses Operational Modes 3 or 4 and requires immediate verification that all insertable control rods are inserted and suspension of all activities that could reduce the Shutdown Margin.

Proposed Action 3.3.A.2 also requires establishment of

dlI8

4 l

secondary containment integrity within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Proposed Action 3.3.A.3 addresses Operational Mode 5 and requires suspension of Core Alterations and other activities that could reduce the Shutdown Margin and insertion of all insertable control rods within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Proposed Action 3.3.A.3 also requires establishment of secondary containment integrity within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The proposed Action provisions address all applicable Operational through limited time for restoration, that Modes and ensure, imitations are enforced or proper remedial shutdown margin l measures are followed.

The proposed SRs implement the present requirement to demonstrate Shutdown Margin provisions di. ring the first startup following a refueling outage in which core alterations were performed.

Added to the present SRs is 4.3.A.l.b, which provides the demonstration of Shutdown Margin within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after detection of a withdrawn control rod that is immovable, as a result of excessive friction or mechanical interference, or is untrippable, except that the Shutdown Margin shall be verified acceptable with the increased worth of the inoperable control rod.

The additional SR for Section 4.3.A implements STS and later operating BWR plant provisions for checking Shutdown Margin when withdrawn control rods are inoperable due to being immovable.

Item 1 This item details the rewrite of present Specification 3.3.A.2/

4.3.A.2 Reactivity Margin - Inoperable Control Rods and its relocatlon to proposed Speci~ication 3.3.C/4.3.C, Control Rod Operability.

The reordering of the specifications in Section 3.3/

4.3 and the new titles are based on STS arrangements and nomenclature.

The proposed LCO for Specification 3.3.C, Control Rod Operability, is taken from a combination of present provisions and STS guidelines.

All control rods are required operable in the applicable operational modes as stated in the STS (and inferred in the present specifications).

The present provision which allows control rods that are fully inserted and disarmed to not be considered inoperable, is deleted.

The proposed Applicability for Specification 3.3.C, of Operational Modes 1 and 2, is taken from STS guidelines.

Present specifications indicate that operability is required during reactor power operation and thus the use of Operational Modes 1 and 2 meets the intent of these present specifications.

The proposed Actions for Control Rod Operability implement STS guidelines and replace present requirements.

Proposed Action 3.3.C.1 addresses the condition where one control rod is inoperable due to being immovable, as a result of excessive friction or mcchanical interference, or known to be untrippable.

Proposed Action 3.3.C.1 requires within one hour, verification that the inoperable rod, if withdrawn, is separated from e 1 other l

inoperable control rods by at least two control cells in all directions, that the control rod be disarmed electrically or hydraulicallyknitiated.and that compliance with SRs 4.3.C.l.b and 4.3.A.l.b be If these conditions are not met, the reactor is required to be in at least Hot Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The inoperable control rod is required to be restored to operable status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or the reactor is required to be in at least Hot Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Proposed Action 3.3.C.2 addresses the condition with one or more control rods trippable but inoperable for causes other than that addressed in Action 3.3.C l.

Proposed Action 3.3.C.2 requires that for withdrawn control rods, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , that inoperable control rods be verified to be separated from all other inoperable withdrawn control re's by at least two control cells in all directions and demonstration of the insertion capability of the inoperable withdrawn control by inserting the control rods at least one notch.

Proposed Action 3.3.C.2 further requires that with the provisions of this Action not met, the inoperable withdrawn control rods be inserted and disarmed.

Provisions are added from the STS to allow the disarmed directional control valves to be rearmed intermittently, under administrative control, to permit testing associated with restoring the control rods to operable status.

Added to the Action provisions of Specification 3.3.C is an exception to the provisions of Specification 3.0.D.

The addition of this exception follows STS guidelines and is required due to the proposed addition of Specification 3.0.D.

Present Quad Cities technical specifications do not contain the restrictions on Operational Mode changes that are contained in STS STS 3.0.4.

Since present Quad Cities technical specifications allow Operational Mode changes while in Action statements, the proposed addition of the exception to 3.0.D does not represent a change from present technical specification provisions.

Present Quad cities technical specifications allow only an electrical disarming of control rod drive directional control valves.

The inclusion of the STS provision to also allow a hydraulic isolation of these valves follows practices that have been proven at many operating BWRs with systems similar to those at Quad Cities.

The present reference to a failed control rod drive collet housing is outdated and is being deleted from the Quad Cities Technical Specilications.

Collet housing cracking and potential failures are detected during control rod disassembly and inspection conducted during regular refueling outages.

Proposed Surveillance Requirements 4.3.C retain precent provisions to exercise control rods weekly and daily while using STS wording

o implement the reguirements.

The present provision for daily control rod tests with three or more inoperable control rods or with one tha; is immovable, is replaced with the STS guideline of daily testing only when any control rod is immovable as a result of excessive friction or mechanical interference.

Implementing this STS SR over present provisions ensures that daily control rod notch movement tests are performed only when there is a demonstrated inability of a control rod to be inserted in the 1

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Present testing provisions would require notch movement tests for three or more slow control rods even though they are still movablq.

Proposed SR 4.3.C.2 is based on STS guidelines and helps to ensure understanding of control rod operability by referencing performanos of SRs 4.3.D, 4.3.G, 4.3.H, and 4.3.I.

Item i This item describes the rewrite of present Specification 3.3.A.3/

4.3.A.3 on Control Rod Position Indication System, to proposed Spesification 3. 3. I/4. 3. I.

Proposed LCO 3.3.I requires all control rod position indicators to be operable in applicable Operational Modes in accordance with STS guidelides and the intent of present specifications.

The proposed Applicability is Operational Modes,,

2, and 5 with the provision that applicability for Operational Hode 5 is only for control rods withdrawn and not for rods removed per Specifications 3.10.D or 3.10.E.

The proposed Appiicability covers all Operational Modes in which control rods avo withdrawn and in which position indication is needed.

Proposed Actions for inoperable control rod position indicators are based on STS guideline and take into consideration the differences between position indication needs at power (Operational Modes 1 or 2) and during refueling (Operational Mode gp,

5).

Proposed Action 3.3.I.1 for Operational Modes 1 or 2 requires i

that with one or more position indicators inoperable, the posit.' n of the rod be determined by an alternate method, or the rod is moved to a position with an operabit indicator, or the rod is declared inoperable, inserted and disarmed either electrically or hydraulically.

If none of the provisions of proposed Action 3.3.I.1 are met, the reactor is required to be in at least Hot Shutduva within the riext 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

A provision is added to provido an exception to Specificati'n 3.0.D.

This exception implements present allowances in the Quad Cities technical specifications and STS guidelines.

The proposed Action steps implement the intent of present Specification 3.3.A.3.b by requirir.g the control rod to be moved to a known position or fully inserted and considered inoperable.

The present requirement to scram the control rod in addition to fully inserting the rod, represents an unnecessary step to ensure proper control rod insertion and is being deleted.

A provision from later operating BWR plants is added to allow rearming control rod directional control valves, under administrative control, to allow for testing associated with returning the control rod to operable status.

Proposed Action 3.3.I.2 addresses Operational Mode 5 and implements STS guidelines to move the control rod to a known position or insert the control rod.

The Action steps for Operational Mode 5 are less stringent than for Operational Modes 1 or 2 due to rod withdrawal limitations and lack of power production.

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Present Surveillance Requirement 4.3. A.3.a requires that once a shift during power operation and during control rod withdrawal, the control rod display shall be observed for contr'a rod position indication.

The intent of the present SR is to ensure that position indication is determined on a frequency that will help to ensure operability of the system.

The intent of this present SR is implemented by proposed SRs 4.4 I.1, 2,

and 3 which are based on STS guidelines.

The STS based SRs, require checking that the position of each control rod is indicated at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , during movement of control rods for the notch movement tests of SR 4.3.C.1 and the " Full out" position test of SR 4. 3. ii. 2.

Present SR 4.3.A.3.b requires that all control rods that have been fully inserted and scrammed be given an insert signal once per shift.

This present SR 4.3.A.3.b is deleted since the present provision of Specification 3.3.A.3.b that requires a.

control rod to be fully inserted and scrammed is being deleted as discossed above.

Item 1 Item 5 describes the rewrite o' present Specification 3.3.B.1/

4.3.B.1 into proposed Specification 3.3.H/4.3.H, Control Rod Drive Coupling.

Present specifications imply control rod coupling is required when control rods can be withdrawn.

The proposed LCO follows present provisions by requiring all control rods to be where control rods can be withdrawn; i.plicable Operational Modes coupled to their drive mechanisms in Ap e.,

Operational Modes 1, 2

and S.

An exception is provided for Operational Mode 5, similar to present Specification 3.3.B.2, such that only control rods that are withdrawn are required to have coupling integrity and not control rods removed per Specifications 3.10.D or 3.10.E.

The proposed LCO and Applicability meet the intent of present specification requirements.

l Proposed Action steps for uncoupled control rods follow STS guidelines and provide separate provisions for power operation (Operational Modes 1 or 2) and for refueling (Operational Mode 5).

Proposed Actions with one control rod uncoupled in Operational Modes 1 or 2 require that within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , if permitted by the RWM, that the control rod be inserted to attempt and to verify recoupling.

If recoupling is not accompllshed on'the first attempt or,'if not permitted by the RWM, then until permitted by the FGM, the centrol' rod is declared inoperable, inserted and-disarmed electrically or hydraulically.

If neither of the above.

l actions are met, then the reactor must be in at least Hot Shutdown l

within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

In accordance with present technical specification allowances and STS guidelines, an exception to the provisions of Specification 3.0.D is added to proposed Action 3.3.H.1.

Proposed Action 3.3.H.2 addresses an uncoupled control L

rod in Operational Mode S.

The proposed Action steps allow within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months either to attempt and to verify recoupling or to insert and disarm the associated control rod.

The proposed Action provisions are more flexible than present provisions by allowing an attempt at recoupling before inserting and disarming the

6 affected control red.

The-allowed recoupling is verified by requiring a-demonstration that the control rod will not go to the overtravel position and; additionally, during Operational Modes 1 and 2 by requiring observation of nuclear instrumentation response.

An STS provision is added to allow disarmed directional control valves to be rearmed intermittently, under administrative control, to permit testing associated with restoring the control rod to operable status.

Present Su Voillance Requirements 4.3.B.1 are changed to match STS guidelines and format.

Present coupling checks after each refueling or maintenance that could affect coupling integrity are retained.

Added to present testing provisions is the requirement to verify each control rod does not go to the overtravel position anytime a control rod is withdrawn to the " Full out" position.

The proposed SRs maintain the intent of present requirements by providing demonstrated testing provisions to help ensure control rod drive coupling integrity.

Item 1 This item details the rewrite of present Specification 3.3.B.3/

4.3.B.2 on Control Rod Drive Housing Supports to proposed Specification 3.3.J/4.3.J.

The proposed LCO requires the control rod drive housing supports to be in place with en Applicability of Operational Modes 1, 2,

and 3.

The proposed LCO and Applicability follow STS guidelines and implement present technical specification provisions.

Present provisions require the control rod drive housing support to be in place during reactor power operation and when the reactor coolant system is pressurized above atmospheric pressure with fuel in the v ssel, unless all control rods are fully inserted and the Shutdown Margin provisions are met.

The proposed applicability of Operational Modes 1, 2,

and 3 cover the reactor conditions of power operation and when the reactor coolant system can be pressurized.

Present Specification 3.3.B.3 contains no Action steps when the control rod drive housing supports are not in place in the applicable Operational Modes.

The proposed Action follows STS guidelines-and is intended to avoid the use of Specification 3.0.A by requiring the reactor to be in at least Hot Shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in Cold Shutdown within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The present Surveillance Requirement for the control rod drive housing supports is rewritten using STS wording as SR 4.3.J.

The l

rewrite is more explicit by requiring a visual inspection prior to startup any time the control rod drive housing support has been disassembled or maintenance has been performed in the control rod drive housing support area.

Iten 2 Present Specification 3.3.B.3.a describes how control rod sequences shall be established to limit maximum reactivity 1L---,,_-

.. ~..

addition due to control' rod dropout so that the rod drop accident design limit of 280 cal /p is not exceeded.

This information should not be contained in the technical specifications but is more appropriately located in the Bases.

Since the present Bases 3.3 contains an adequate discussion on this topic, present Specification 3.3.B.3.a is deleted.

Present Specifications'3.3.B.3.b and 4.3.B.3 contain requirements j

for the Rod Worth Minimizer.

These present Specifications are rewritten using STS guidelines as Specifications 3. 3. L/4. 3. L.

The proposed LCO requires the RWM to be operable with-Applicability of Operational Modes 1 and 2, when thermal power is less than 20% of rated thermal power.

An exception to RWM operability allows it to be bypassed for low power physics testing to demonstrate shutdown margin requirements of Specification 3.3.A if a technically qualified individual.is present and verifles the step-by-step rod movements of the test procedure.

The proposed LCO and Applicability statements are taken from provisions of present Specification 3.3.B.3.b and arranged in an STS format.

Proposed Action steps for an inoperable RWM-are taken from STS

. guidelines and allow a second licensed operator or technically qualified individual who is present at the reactor control console to verify rod movement and compliance with the prescribed control rod pattern.

Otherwise, control rod movement is allowed only by actuating a reactor scram by placing the reactor mode switch in the' Shutdown position.

The proposed Action steps are different from present provisions since presently, at least 12 control rods must be fully withdrawn before a second operator or qualified technical person can be used as a substitute for the RWM.

There L

is no real basis for the present requirements other than good judgement and a desire to begin a reactor startup with an operable RWM.

The proposed Action steps provide adequate assurance that i

control rods will be withdrawn in accordance with prescribed patterns without the necessity of requiring 12 control rods to be f.

fully withdrawn before a substitute can be used for the RWM.

l Proposed Surveillance Requirements 4.3.L for the Rod Worth-l=

Minimizer are taken from present testing provisions and STS guidelines.

Verification of the selection error-of at least one l

out-of-sequence control rod is performed in Operational Mode 1 prior to reducing thermal power below 20% and in Operational Mode 2 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to withdrawal of control rods to make the l

reactor critical.

Testing to demonstrate the inability to with-draw an out-of-sequence control rod is performed in Operational Mode ~1 prior to reducing thermal power below 20% Rated Thermal Power and in Operational Mode 2 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months prior to withdrawal of control rods to make the reactor critical.

The RWM at Quad Cities is normally active at all reactor power levels and thus tetting can be performed at > 20% Rated Thermal Power.

Proposed SR 4.3.L.4 provides verification -that the control rod patterns and sequence input to the RWM computer are-correctly loaded following any loading of the program into the computer.

Proposed SR 4. 3.L.4 replaces present SR 4.3.B.3.a which requires the successful

- -... ~. -

e i

completion of the RWM computer online diagnostic test prior to the start of control rod withdrawal towards criticality.

Item a Item 8 describes the rewrite of present Specification 3.3.D.4/

4.3.B.4 on Source Range Monitoring Function to proposed Specification 3.3.N/4.3.N.

Specification 3.3.N/4.3.N on SRM function is different from the SRM requirements in Section 3.2/4.2 and 3.10/4.10.

The SRM function in Specification 3.3.N/4.3.N only involves the monitoring capability of the operator from the control room in Operational Modes 2, 3,

and 4.

In Section 3.2/4.2, Tables 3.2-3 and 4.2-1 contain the Rod Block function requirements for the SRMs.

In Section 3.10/4.10 the refueling Operational Mode requirements for the SRMs are detailed.

The present LCO for the Source Range Monitoring Function requiring at least two SRM channels to be operable in Operational Modes 2, 3,

and 4 is expanded-to require three operable SRMs for Operational Mode 2.

The proposed Applicability of Operational Modes 2, 3,

and 4 follows STS guidelines with the Applicability in Operational Mode 2 required only when IRM's are on range 2 or below.

The proposed exception in Operational Mode 2 ensures that IRMs are adequately on scale before SRMs are not required to be operable.

Proposed Action steps for the Source Range Monitoring function follow STS guidelines.

Present requirements preventing control rods from being withdrawn for startup or refueling unless at least the required number of SRMs have an observed count rate of at least three counts per second and are fully inserted, are retained in the proposed specification.

Proposed Actions for incperable SRMs are divided into steps for Operational Mode 2 and separate steps for Operational Modes 3 or 4.

In accordance with ST3 guidelines, in Operational Mode 2 with one of the required source range monitor channels inoperable, proposed Action 3.3.N.1 requires that the channel be restored to operable status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or else being in at least Hot Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The present requirement of an observed count rate of at least 3 counts per second with the SRMs fully inserted, is implemented through performance of proposed Surveillance Requirement 4.3.N.1 just prior to withdrawal of control rods.

Proposed Action step 3.3.N.2-for Operational Modes 3 or 4 with one or more SRM channels inoperable, requires verification that all insertable control rods are inserted in the core and that the reactor mode switch is locked in the Shutdown position within one hour.

The provisions of proposed Action 3.3.N.2 are taken from STS guidelines and are intended to ensure that with required SRMs inoperable in Operational Modes 3 or 4, conditions exist to ensure that all insertable control rods are full inserted and to prevent the possible withdrawal of any control rodo Proposed Surveillance Requirement 4.3.N.1 implements present SR 4.3.B.4 by recuiring verification, prior to control rod withdrawal

that the SRM count rate is at least 3 counts per second with the detector fully inserted.

Proposed SR 4.3.N.2 adds Channel check, Channel Calibration, and Channel Functional Test requirements cased on STS guidelines.

Item 1 This item describes the rewrite of present Specification 3.3.B.5/

4.3.B.5 to proposed Specification 3.3.M/4.3.M, titled i' Rod Block Monitor".

The proposed LCO implements present requirements by requiring both RBM channels to be operable.

However, the present provision of requiring the RBM operable only during limiting control rod patterns is replaced with the STS Applicability provision of Operational Mode 1, when thermal power is greater than or equal to 30% of rated thermal power.

An exception to the proposed Applicability is taken from present Note 1 on Table 3.2-3 which allows one RBM channel to be bypassed above 30% rated thermal power without a time restriction provided a limiting control rod pattern does not exist and the remaining RBM channel is operable.

A clarifying statement is added to the Applicability to reflect RBM system design where both RBM channels are

+ automatically bypassed when a peripheral control rod is selected.

Proposed Action steps for the RBM are based on STS guidelines.

Action 3.3.M.1 requires that with one RBM channel inoperable and not bypassed, verification be made that the reactor is not operating in a limiting control rod pattern and that the inoperable RBM channel be restored to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If these Action provisions are not met, then the inoperable RBM is required to be in the tripped condition within one hour.

Proposed Action 3.3.M.2 addresses the condition where both RBM channels are inoperable and requires that at least one be in the tripped condition within one hour.

The proposed Action steps meet the intent of present requirements by requiring the blocking of control rod withdrawal when a limiting control rod pattern exists.

Present requirements do not contain time frames for accomplishing Action steps and; thus, STS time frames are utilized.

The Surveillance Requirements for the RBM channel are taken from present technical specification requirements.

SR 4.3.M.1 references Table 4.2-1 in order to avoid duplicating the SR listing.

Proposed SR 4.3.M.2 requires a channel functional test prior to control rod withdrawal when the reactor is operating in a limiting control rod pattern and daily thereafter, and is taken from present SR 4.3.B.5.

Item 12 The present specifications for the scram discharge volume vent and drain valves, 4.3.B.6, address only the Surveillance Requirements and do not contain LCO, Applicability or Action provisions.

The proposed rewrite uses NRC accepted provisions at other operating BWRs to address the missing requirements in the Quad Cities

i l

Technical Specifications.

Proposed Specifications 3.3.K/4.3.K address the operability of the scram discharge volume vent and drain valves.

The proposed LCO requires all scram discharge volume vent and drain valves to be operable with an Applicability of Operational Modes 1 and 2.

Operational Modes 1 and 2 were chosen since these are the only conditions where multiple rod scrams are needed and thus the operability of the affected vent and drain valves are required to ensure system integrity.

Proposed Action 3.3.K.1 addresses the condition where one scram discharge volume vent valve or one scram discharge volume drain valve is inoperable and open; or, a combination of any one scram discharge volume vent valve and any one drain valve are inoperable wr.d open.

The valve (s) are required to be restored to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the reactor shall be in at least Hot Shutdown within the next.12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Proposed Action 3.3.K.2 addresses all other possible combinations of vent and drain valve inoperability other than those addressed in Proposed Action 3.3.K.1 and requires the valve (s) to be returned to opercble status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or the rea: tor shall be in at least Hot Shutdown within the next 12 houra.

The proposed Action steps' address r,acessary conditions of inoperability for the scram dischatgo volume vent and drain valves and provide reasonable out of service times for repales.

Present Surveillance Requiretcents for the scram discharge volume vent and drain valves are reformatted but retained as proposed SR 4.3.K.

11am 11 Item 11 provides the description of the separation of present Specification --3.3.C/4.3.C on Scram Insertion Tiroes into three separate specifications in accordance with STS guidelines.

Proposed Specification 3.3.D/4.3.D on Control Rod Maximum Scram Insertion Times is taken from present Specifications 3.3.C.2/4.3.C, proposed Specification 3.3 E/4.3.E on Control Rod Average Scram Insertion Times from present Specification 3.3.C.1, and proposed Specification 3.3.F/4.3.F on Four Control Rod Group Scram Insertion Times from present Specification 3.3.C.1.

Proposed Specification 3.3.D/4.3.D on Control Rod Maximum Scram Insertion Times is written using present LCO provisions which require that the maximum scram lnsertion time to 90% inserted for any operable control rod shall not exceed 7 seconds.

The proposed Applicability of Operational Modes-1 and 2 implements ST3 guidelines and requires maximum scram insertion times to be met in the reactor conditions where multiple rods can be withdrawn and where accident analyses depend on these insertion limits.

Proposed Action steps for Specification 3.3.0 are based on STS and present provisions and are written to allow some operational flexibility in comparison with present provisions.

Present Specification 3.3.C.4 requires control rods not meeting the l

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l

4 d

maximum scram-insertion time limits to be declared inoperable, fully inserted into the core and electrically disarmed.

Proposed Actions 3.3.D.1 and 2 require the affected control rod to be declared -inoperable and require performance of SR 4.3.D.1.c at least once per 60 days when operation is continued with three or more control rods with maximum scram insertion times exceeding 7 seconds.

SR 4.3.D.1.c requires maximum scram time tests for at least 10% of the control rods.

If Actions 3.3.D.1 and 2 are not met then Action 3.3.D.3 requires that the reactor be placed in at least Hot Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Added to the Action provisions for Control Rod Maximum Scram Insertion Times is an exception to the provisions of Specification 3.0.D.

The proposed restrictions in proposed Specification 3.0.D on operational Modo changes while in Action statements represent re@irements that are not currently in the Quad Cities technical specifications.

The inclusion of the i

exception to the provisions of Specification 3.0.D retains current operating allowances and implements STS guidelines.

The-surveillance Requirements proposed for the Control Rod Maximum Scram Insertion Time, 4.3.D incorporate some present requirements and offer revisions to requ1rements based on STS guidelines.

-Present SR 4.3.C.1 provisions to perform scram time tests on all control rods after a refueling and before exceeding 30% power are modified in proposed SR 4.3.D.1 by requiring the SR prior to exceeding 30% power following core alterations or after a reactor shutdown that is greater than 120 days.

Scram time testing is-added by-SR 4.3.D.1.b for individual control rods following maintenance or modification work that could affect scram times.

These changes will ensure testing in situations that can directly affect control rod insertion times.

An exception to the provicions of Specification 4.0.D is added to proposed SR 4.3.D.1.b to allow entry into Operational Mode 2 provided the surveillance is performed prior to entry into operational Mode 1.

This-exception has been used by some later operating BWRs to allow entry into necessary reactor operational Modes in order to perform the "esting without violating the intent of proposed Specification 4.0.b.

Presently, SR 4.3.C.2 requires that all control rods be scram time tested each year and further that-50% of the control rods in each quadrant of the reactor core to be measured for scram i

times not more frequently _than 16-weeks nor less frequently than 32 weeks.

These present requirements are replaced with proposed SR 4.3.D.1.c which is STS based and requires at least 10% of the l

control rods, on a rotating basis, to be scram time tested at L

least once per 120 days of reactor power operation.

The reduced l

scram time testing of proposed SR 4.3.D.l.c has been proven successful through use for detecting scram time deterioration at later operating BWRs with control-rod drive systems similar in l

design to that of Quad Cities.

The requirement in present SR j:

4.3.C.2 to perform evaluations after completion of control rod drive scram tests is being deleted since the Surveillance Requirements as proposed require, through their performance, evaluations of control rod drive scram tests.

The requirement to submit the results of the scram time tests in the annual operating l

. - ~ -- -- - - - - - ~ - - - -

l i

report to the NRC is not a necessary technical specification requirement and is being deleted.

Present SR 4.3.C.3 to determine the cycle-cumulative mean scram time for 20% insertion is being retained as SR 4.3.D.2.

The Action provisions contained in present SR 4.3.C.3 have been deleted since they already appear in proposed Action 3.3.E.2.

Proposed Specification 3.3.E/4.3.E on Control Rod-Average Scram Insertion Times is written from present requiremente in Specification 3.3.C.1 and STS guidelines.

Proposed LCO 3.3.E uses present specification requirements with STS wording.

The LCO requires the average scram insertion time of all operable control rods from the fully withdrawn position based on doenergization of the scram pilot valve solenoids as time zero, to meet the specified limits.

The proposed Applicability is Operational Modes 1 and 2 in order to ensure control rod insertien times are adequate for power operating conditions.

l Proposed Action 3.3.E.1 requires that with the average scram insertion time exceeding any of the limits, the reactor be in at least Hot Shutdown within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

This shutdown provision implements the intent of present Specification 3.3.C.3.

Proposed Action 3.3.E.2 implements present provisions of Specification l

3.3.C.S in requiring MCPR operating limits adjustments with the overall-average of the 20% lnsertion scram insertion times exceeding Core Operating Limits Report assumptions.

The Surveillance Requirements for proposed Specification 4.3.E l

reference the scram time testing requirements of proposed Specification 4.3.D as discussed above, l

Proposed Specification 3.3.F/4.3.F provides requirements for Four Control Rod Group Scram Insertion Times based on the provisions of present Specification 3.3.C.1/4.3.C.

The proposed LCO is written from present Specification 3.3.C.1 requirements that the average of the scram insertion times for the three fastest control rods of all groups of four control rods in a two by two array shall meet the stated limits.

The Applicability is Operational Modes 1 and 2 in order to require compliance in those reactor power operating l

conditions where control rod scram time assumptions are needed.

Proposed Action requirements are taken from STS guidelines.

Proposed Action 3.3.F.1 allows more flexibility than present Specification 3.3.C.1 by requiring the control rods with slower than average scram insertion times to be declared inoperable until an analysis is performed to determine that required scram reactivity remains for the slow four control rod group.

Action i

3.3.F.1 further requires performance of scram time testing in I

accordance with SR 4.3.D.1.c at least once per 60 days when operation is continued with an average scram insertion time in excess of the specified limit.

If these provisions of proposed Action 3.3.F.1 are not met, then the reactor is required to be in at least Hot Shutdown within thn next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

An exception to the provisions of Specification 3.0.D is added ir. accordance with present technical specification allowances and STS guidelines.

= - -. - -

The Surveillance Requirements of Specification 4.3.F reference the provisions of SR 4.3.D for control rod scram time testing.

Item 12 This item describes the rewrite of Present Specification

- 3. 3.D/4. 3. D on-Control Rod Scram Accumulators into proposed Specification 3.3.G/4.3.G based on present anu STS provisions.

The proposed LCO requires all control rod scram accumulators to-be operable with Applicability of Operational Modes 1, 2,

and 5.

An exception is provided for Operational Mode 5 such that the requirements are only for withdrawn control rods and not for control rods that are removed por Specifications 3.10.D or 3.10.E.

The present exception, that allows the rod block associated with an inoperable accumulator to be bypassed is deleted.

The proposed Applicability covers the operational Modes in which control rods can be withdrawn and thus also covers the operating conditions where accumulators may need to perform their intended function.

. Proposed Actions for inoperable control rod scram accumulators do not address the present out dated nine-rod square array requirements, but do implement STS guidelines to help ensure necessary safe plant operation in this condition.

Proposed Action 3.3.G.1 addresses Operational Modes 1 or 2 and requires with one control rod scram accumulator inoperable, within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months action be taken to restore the inoperable accumulator to operable status or 4

declare the associated control rod inoperable.

If more than one control rod scram accumulator is inoperable in Operational Modes 1 or 2 control rod drive pump operability must be verified, if the affected control rod (s) is withdrawn, by inserting at least one withdrawn control rod'at least one notch or the reactor mode switch must be placed in the Shutdown position.

Also, the affected control rods must be inserted and disarmed.

If any of these Action steps are not met, then the reactor must be in at least Hot Shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

In Operational Mode 5 the action statements require that with one withdrawn. control rod with its associated scram accumulator inoperable, the associated control rod be inserted and disarmed.

With more than one withdrawn control rod with an associated scram accumulator inoperable in Operational Mode 5, the reactor mode switch is required-to be placed in the Shutdown position._ The proposed l

Action statements offer some flexibility over present outdated nine-rod square array provisions but still provide adequate controls to ensure that the control rod scram function is not compromised.

The present Surveillance Requirements of 4.3.D-that require checking at least once per shift the status of pressure and level alarms, are replaced with weekly STS testing guidelines.

Proposed l

SR 4.3.G added from STS guidelines requires at least once per 7 days that the pressure for each control rod scram accumulator be verified to be > 950 psig, unless the control rod is inserted and

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