ML20085C757

Application for Amends to Licenses DPR-29 & DPR-30, Reflecting Util Efforts to Upgrade Existing TS Sections 3.5/4.5, Core & Containment Cooling Sys & 3.6/4.6, Primary Sys Boundary, as Part of TS Upgrade Program

ML20085C757
Person / Time
Site:	Quad Cities
Issue date:	10/02/1991
From:	Schrage J COMMONWEALTH EDISON CO.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20085C759	List: ML20085C757 ML20085C760
References
NUDOCS 9110110108
Download: ML20085C757 (35)

Text

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, ([ ; / 1400C:mm:nwealth Opus PlaceEdison

. \ Downers Grove. Illinois 60515 October 2,1991 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 03erating Licenses DPR 29 and DPR-30, Append x A, Technical ,

Specifications 1 Technical Specification Upgrade Program NBC30cheLNosm50-25 Land.50-265 Dr. Murley:

In 1990, Quad Cities Station initiated a formal program to enhance Le Station's performance in various aspects of plant operation. The Performance Enhancement Program (PEP) was developed by assessing existing improvement alans, identifying potential weaknesses and prioritizing improvement actions.

9ecessary improvements to the Technical Specifications were identified as one of the i Station top priority issue. Details of the goal and methodology for the Technical Specification Upgrade Program are provided in the Executive Summary section of the proposed amendment. The Program has been previously discusced with members of the NRR staff.

Pursuant to 10 CFR 50.90, Commonwealth Edison proposes to amend Appendix A, Technical Specifications to Facility Operating Licenses DPR-29 and DPR-30. The proaosed amendment reflects Commonwealth Edison's efforts to upgrade existing""echnical Specification Sections 3.5/4.5 " Core and Containment Cooling Systems ,3.6/4.6 " Primary System Boundary" and 3.7/4.7 " Containment Systems". An overall description of the proposed amendment is also irmluded in the Executive Summary.

The proposed amendment request for each Technical Specification section is ,

provided as follows:

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

2. A summary of the changes;

3. A detailed description of the changes; I

4. The proposed Technical Specification pages with 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 Technical Specifications.

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6 Dr. Thomas E. Murley October 2,1991 The aroposed amendment has been reviewed and approved by Commonwealt1 Edison's on-site and off site review in accordance with Company procedures.

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

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

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

Please direct any questions concerning this proposed amendment to J. Schrage at 708/515-7263.

Ve7 truly yours,

/ John L. S ,l/f&'lage  %'n Nucle'ar Licensing Administrator Enclosure (A : 3.5/4.5 " Core and Containment Cooling Systems" (B : 3.6/4.6 " Primary System Boundary" (C : 3.7/4.7 " Containment Systems" cc: A.Bert Davis, Regional Administrator I..N. Olshan, Project Manager T.E. Taylor, Senior Resident inspector Illinois Department of Nuclear Safety State of 5d , County of Signed hefers rne on Nq4dday (' ~ ~ ~ ~ ~ ~ ~ ~ ,

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QUAD CITIES NUCLEAR POWER STATION

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UPGRADE PROGRAM P

r b PROPOSED AMENDMENT I SECTION 3.5/4.5 " Core & Containment Cooling Systems" r) "

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EXECUTIVE

SUMMARY

e Proposed Changes to TS 3.5/4.5

, ' CORE & CONTAINMENT COOLING SYSTEMS" e

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EXECUTIVE BUKMARX g QUAD CITIES TECHNICAL JP' JIFICATION UPGRADE PROGR=M The Quad Cities Technical Specification Upgrade Program was

( conceptualized in response to lessons learned from the Dresden l

6 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 opera *.ing plants' Technical Specification provisions was conducted to ide 44 % patential improvements in clarifying requirements and to identify l, 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 Jtandard Technical specifications. Overall, the Quad Cities custom Technical specifications provide for a safe operation of the plant and, therefore, only an upgrade was deemed J

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 i, 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 Oraration cannot be met. The Technical Specification Upgrade Program also implements NRC recommended line item improvements to the Technical Specifications which were issued under Generic Letters.

3 In response to an NRC recommendation, the Unit 1 and Unit 2 Technical Specifications are combined into one document. To accomplish the combination of the Units' Technical Specifications, a comparison of the Unit 1 and 2 Technical Specifications was performed to identify any technical differences. The technical

}, differences are identified in the proposed amendment package for

> each section.

The Technical Specification Upgrade Program was identified as a Station top priority during the development of Quad Cities Station's Performance Enhanceacnt Program (PEP). The Technical Specification Upgrade Program's goal is to provide a better tool J 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 8 actions. The most significant improvement to the specifications is the addition of equipment operability requirements during shutdown conditions.

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RKECUTIVE

SUMMARY

-(Continuedl, yE Proposed Technical Specification Section 3.5/4.5, " Core & Containment Cooling Systems" The present Quad Cities technical specifications contain Applicability and Objective statements at the beginning of most j' -sections._ Under the proposed change, each Specification will contain'an LCO, Applicability, Action and Surveillance Requirement section, as applicable._- The bases of the-technical specifications are relocated to the end of the section.

The changes proposed will provide an STS type of format while y retaining the present two column layout.

Post-maintenance testing requirements are deleted from the

-specifications since this type of testing is included in ,'

maintenance procedures and is already understood to be a part of the definition of system _ Operability.

Some multiple testing of other ECCS systems when one system is inoperable has been deleted from the specifications. More recent BWR technical specifications. accept system operability based on satisfactory performance of monthly, quarterly, refueling interval, post maintenance and other performance tests witnout requiring additional' testing when another system is inoperable.

To eliminate unnecessary duplication, quarterly pump and valve operability tests-have been deleted from'the specificationc since demonstration of their operability is already achieved on a

-quarterly basis by we Quad Cities Inservice Testing Program, k For plant operating conditions, the proposed changes separate present Specification 3.5.A/4.5.A into two distinct- '

. specifications: 3.5.A/4.5.A-for the Core Spray Subsystem and

-3.5.B/4.5.B for the LPCI Mode of the RHR System. Cold Shutdown and Refuel requirements for the Core Spray and RHR systems are contained in_ proposed Specification 3.5.H/4.5.H.

Also for. plant operating conditions, the proposed changes separate' present Specification 3.5.B/4.5.B into two distinct specifications: 3.5.C/4.5.C for the Containment Cooling Mode of RHR and 3.5.D/4.5.D for the Containment Cooling Spray Loops.

.Two. distinct specifications, 3.5.H/4.5.H for the Minimum Core and Containment Cooling System Availability - Plant Shutdown and new 3.5.I/4.5.I for' Suppression Chamber Requirements _for Core and Containment Cooling Systems are proposed as a replacer > at for existing Specification 3.5.F/4.5.F.

E The proposed changes include-the rewrite of present Specification 3.5.G/4.5.G into two distinct Specifications: 3.5.J/4.5.J for Maintenance of Filled Discharge Pipe for Core Spray, LPCI Mode of f

RHR and the RHR loops used to satisfy proposed Specification 3.5.H; and Specification 3.5.K/4.5.K for Maintenance of Filled Discharge Pipe for RCIC and HPCI.

3-To ensure sufficient overlap with the low pressure ECCS systems capability to inject water to the reactor vessel and to provide consistency with the operability requirements for HPCI and RCIC, the Operational Mode 1, 2 and 3 Applicability of the Automatic Pressure Relief Subsystem is proposed to be changed from the existing reactor pressure >90 pLig to >150 psig.

Based on the positive performance recorf of relief valves since 1984, the proposed changes extend the surveillance testing interval for the manual opening of each relief valve from the present 6 month frequency to the STS guidelire of 18 months.

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SUMMARY

OF CHANGES 3

PROPOSED TS 3.5/4.5 3 ' CORE & CONTAINMENT COOLING SYSTEMS' D

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D AHNiAM DI CJihRQlia PROPOSED SPECIFICATION 3.5/4.5 I CORE AND CONTAINMENT COOLING SYSTEMS

] This amendment package is one in a series of proposals that *'ill l provide improvements to the present Quad Cities Technical  !

Specifications. The summary of changes includes a general section i to describe generic changes that are applicable to more than one l section of the technical specifications and a section which i provides the changes that are page by page specific.  !

GENERIC CHANGES Item 1:

The present Applienbility and objective statements at the beginning of each technical specification section are being D deleted. The Applicability statement is being included after the LCO statement in each individual specification.

Item 2:

Each specification is rearranged to follow an STS type of format while retaining the present two column layout. Each specification 3 will contain an LCo, Applicability, Action and Surveillance Requirement section, as applicable.

Item 3 9

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

SPECIFIC CHANGES Item 1:

4 Pacca 3.5/4.5-1 throuch 3.5/4.5-3, specificatiOD lx52h/4.5.A. DPR-12

a. Present Specification 3.5.A/4.5.A is rewritten such that the Core Spray and LPCI Mode of the RHR System requirements are m separated into two distinct specifications, 3.5.A/4.5.A and "J

3.5.B/4.5.B, respectfully.

b. The proposed LCO and Action requirerents for Core Spray and the LPCI Mode of RHR are based on present technical specification provisions with the exception cf the reactor shutdown provisions of Actions 3.5.A 3 and 3.5.B.3, and Action O 3.5.A.2 for Core Spray header dp. These shutdnwn provisions O

D 4 are based on STS provisions and require the reactor to be in at least Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Proposed Action 3.5.A.2 allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore an inoperable Core Spray header dp instrument channel or the dn must be determined locally at least once por 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If these provisions are not met, the associated Core Spray subsystem is declared 8 inoperable. The remedial measures in present Action 3.5.A.5 for the LPCI mode of the RHR system being inoperable are clarified by indicating that for the containment cooling mode of the RHR, ADY two RHR pumps are required operable.

c. The proposed Applicanility is operational Modes 1, 2, and 3 g and implements present intent.

d. The proposed Surveillance Requirements are based on present requirements, Inservice Testing provisions and STS guidelines.

The monthly pump runs and valve stroke tests are deleted since the Quad Cities Innervice Testing Program includes the valves and a quarterly pump flow rate test. The monthly valve e operability check is replaced with an added monthly valve position verification check. present post-maintenance testing requirements in Specification 4.5.A.1.b are deleted in the proposed amendment since this type of testing is included in maintenance procedures and is already understood to be a part of the definition of system Operability. Surveillance

, Requirements 4.5.A.2, 4.5.A.4, and 4.5.A.5 are deleted based v on plant operating experience which has demonstrated that multiple testing of other ECCS systems when one system is inoperable is not necessary to provide adequate assurance of system operability. Also, more recent BWR technical specifications accept system operability based on satisfactory performance of monthly, quarterly, refueling interval, post a~

maintenance and other specified performance tests without requiring additional testing when another system is inoperable. Present core spray header dp instrumentation check, calibration, and test are changed to channel check, channel calibration and channel functional test. Present quarterly Core Spray header dp instrument channel calibrations are changed to refueling in accordance with STS guidelines.

O The present provisiont of Specifications 3.7.C.2/4.7.C.2, concerning the closure of the doors for the core spray and RHR pump compartments, are moved to proposed SR 4.5.A.6.

Item 2:

q Paces 3.5/4.5-3. 3.5/4.5-4. And lu5/4.5-5. SaccificatjQD

" 3.5.B/4.5.B. DPR-29

a. Present Specification 3.5.B/4.5.B is rewritten such that the Containment Cooling Mode of the RHR System and the Containment Cooling Spray Loops requirements are separated into two distinct specifications, 3.5.C/4.5.C and 3.5.0/4.5.0, O respectfully.

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D b. The proposed LCO and Action requirements for the Containment Cooling Mode of the RHR System and the Containment Cooling Spray Loops are based on present requirements with the exception of the reactor shutdown provisions of Actions 3.5.C.3 and 3.5.D.J. These reactor shutdown provisions are based on STS gui(.elines and require the reactor to be in at E

least Hot Shutdevn within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Also, proposed Action 3.5.D.2 addressas the condition where the containment spray loops are inoperable for reasons other than one dryvell spray loop being inoperab?e. Present Specification 3.5.B.1.a reference to the Bases for Specification 3.5.B in deleted.

B c. The proposed Applicability is operational Modes 1, 2, and 3 and implements present intent.

d. The proposed Surveillance Requirements are based on present requirements and the Quad Cities Inservice Testing Program provisions. Therefore, as in paragraph 1.d above, monthly pump runs and valve stroke tests are deleted. Present SRs D 4.5.B.2 and 4.5.B.3 are deleted for the same reason as SRs 4.5.A.2, 4.c.A,4 and 4.5.h.6 as discussed above in paragraph 1.d. Post-E"intenance testing provinicns of present Surveillance Requirement 4.5.B.1.b are deleted since this type of testing is included in maintenance procedures and is already understood to be a part of the definition of syLtem perability. Monthly valve position verification checus are D added,

c. The present one time exception of Specification 3.5.B.1.b is dsloted.

Item 3:

B Panes 3.5/4.5-5. and 3 5/4.5-6, Specification 3.5.C/4.5.C. DPR-29

a. The HPCI Subsystem Specifications were amended in a submittal to the NRC dated May 25, 1989. The proposed changes in this submittal are based on the changes from the earlier submittal.

Present Specification 3.5.C/4.5.C is rewritten as proposed D Specification 3.5.E/4.5.E.

b. The proposed LCO, Actior s and Surveillance Requirements are based on proposed changes in the previous submittal referenced above. The proposed ActionL from the previous submittal are modified to delete post-maintenance testing. The proposed D Surveillance Requirements from the previous submittal are modified to reference proposed Specification 4.0.D for an exception to allow entry into Operational Modes to allow to reference 4.0.E for the Inservice Testing Program testing,ing for test frequency on the HPCI pump, and to delete post-maintenance testing since this type of testing is included in maintenance procedures and is already understood to be a part D of the definition of system opernbility .

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3 e c. The proposed Applicability is Operational Mode 1 and Operational Modes 2 and 3 whenever reactor pressure is greater than 150 psig.

Item 4:

Pacea 3.5/4.5-6 and 3.5/4.5-7. Soecification 3.5.D/4 13Q2 2 DPR-29 e Present Specification 3.5.D/4.5.D, Automatic Pressure Relief Subsystems, is rewritten as proposed Specification 3.5.r/4.5.F, Automatic Pressure Relief Subsystems - Plant Operating.

g b. The proposed LCO, Actions and Surveillance Requirements for the Automatic Pressure Relief Subsystems are based on STS guidelines. All five relief valves are required operable.

With one of the required relief valves inoperable and with the HPCI, both core spray systems, and the LPCI mode of RHR operable, 14 days is allowed before initiating a plant shutdown. With two or more cf the required 4 relief valves inoperable, the plant is required to be in at least Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor vessel pressure to s 150 psig within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

c. The proposed Applicability is Orerational Mode 1 and Operational Modes 2 and 3 whenever reactor pressure is greater

, than 150 psig.

d. Based Jn STS guidelines, an exception to proposed Specification 4.0.D is added to proposed Surveillance Requirement 4.5.F.1 to allow entry into the Operational Modes for testing the relief valves. Present provisions to verify relief valve opening during testing is exaanded to include e indication by a corresponding change in tae measured steam flow. Present Surveillance Requirement 4.5.D.4 is deleted based on the earlier justification provided in paragraph 1.d regarding multiple system testing. Based on relief valve performance records, the present surveillance interval in SR 4.5.D.1 is changed from 6 months to 18 months in accordance

, with STS guidelines.

J Item St Paces 3.5/4.5-7 and 3.5/4.5-8. Specification 3.5.E/4.5.E. DPR-?d

a. The RCIC System Specifications were amended in a submittal g dated May 25, 1989. The changes proposed in this amendment request are based on the changes in the earlier submittal.

Present Specification 3.5.E/4.5.E is rewritten as proposed Specification 3.5.G/4.5.G, Reactor Core Isolation Cooling System - Plant Operating.

b. The proposed LCO, Actions, and Surveillance Requirements are e based on proposed changes in the previous submittal referenced O

) above. Proposed Action 3.5.G.1 from the previous submittal is modified by deleting post-maintenance testing requirements and proposed Action 3.5.G.2 is modified by requiring the reactor to be in at least Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to reduce reactor vessel pressure to 5 150 psig within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The proposed Surveillance Requirements from the previous submittal are ac41fied to reference proposed specification 4.0.D for an exception to allow entry into operational Modes for testing and to delete post-maintenance testing since this type of resting is included in maintenance procedures and is alrear, enierstood to be a part of the definition of system opcrabi.ity.

'1 c. The proposed Applicabil.ty ic Ope *.ational Mode 1 and Operational Moder. 2 and . yl ener .r reactor pressure is greater than 150 psig.

Item 61 Paces 3.5/4.5-8 and 3.5/4.5-9. SDecification 3.5.F/4.5.F. DPR-29

) a. Present Specification 3.5.F/4.5.F is rewritten such that the l Minimum Core and Containment Cooling Systems Availability requirements and the Suppression Chamber Requirements are separated into two distinct specifications, 3.5.H/4.5.H and 3.5.I/4.5.I, respectively. Proposed LCO 3.5.H requires at

) leact two pumps from Core Spray or RHR to be operable in Operational Modes 4 and 5 with exceptions to allow all low pressure core and containment cooling systems to be inoperable in operational Mode 5, with certain limitations based on STS guidelines.

b. Proposed Applicability is Operational Modes 4 and 5 for

} Specification 3.5.H.

c. Proposed Actions 3.5.H.1 and 3.5.H.2 are baced on STS guidelines,

d. Present Surveillance Regairement 4.5.F is changed 6o reference 3 Specifications 4.5.A and 4.5.B.

e. Proposed LCO and Actions 3.5.I for the Supprension Chamber Requirements for Core and Containment Cooling Systems are based on STS guidelines and replace the provisions of present Specifications 3.5.F.3 and 3.5.F.4. Suppression Chamber water level requirements in Operational Modes 4 or 5 are changed to

)- at least 7 feet above the bottom of the Suppression Chamber.

f. Proposed Applicability for Specification 3.5.I is Operational Modes 1, 2, 3, 4, and 5.

g. New surveillance requirements proposed for Specification 3.5.I 3 require checking suppression pool water level at least once F.

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> per day and verifying LCo conditions are met when the suppression chamber level is less than the limit or drained in operational Modes 4 or 5.

h. Present Specification 3.5.F.1 is deleted.

Item 7.3 Paqos 3.5/4.h-12 and 3.5/4.5-11. Specification 3.5.G/4.5.G. DPR-29

a. Present Specification 3.5.G/4.5.G on Maintenance of Filled Discharge Pipe is rewritten as two Specifications, 3.5.J/4.5.J, Maintenance of Filled Discharge Pipes for Core LPCI Mode of RHR, and the RHR Loops Used to Satisfy g

Spray,ication Specif 3.5.H, and 3.5.K/4.5.K, Maintenance of Filled Discharge Pipe for RCIC and HPCI.

b. The LCo, Applicability, and Surveillance Requirements for proposed Specifications 3.5.J/4.5.J and 3.5.K/4.5.K are taken from present requirements with the exception of Surveillance

> Requirement 4.5.K.1 which is a new provision for HPCI and RCIC. The present upper limit of 90 psig, for the discharge pipes for Core Spray, LPCI mode of RHR and the loops used to satisfy Specification 3.5.H, is deleted. Post-maintenance testing provisions of present Specification 4.5.G.2 are deleted.

I c. The requirement to initiate corrective action within one hour and the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> restoration requirement of proposed Action 3.5.J.2 are based on present provisions. Proposed Action 3.5.K.1 to restore CST level within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or line up both HPCI and RCIC to take a suction from the Suppression Chamber is taken from present provisions. He w Action provisions, p as a part of proposed Actions 3.5.J.2 and 3.5.K.2, require declaring the affected system inoperable if the fill system is not restored within allowable time limits or other provisions are not met and are based on STS guidelines. Proposed Action 3.5.J.1 is taken from STS guidelines and requirew performance of SR 4.5.J.1 at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with a discharge line keep filled pressere alarm channel inoperable. Present

> provision in Specification 3.5.G.2 that requires with the discharge pipe prnssure outside the limits that this condition be alarmed in the control room, is deleted.

Item 8:

g Panes 3.5/4.5-11 and 3.5/4.5-12. Specification 3.5.H/4.5.H. DPR-29

a. Change the Specification number to 3.5.L/4.5.L for the Condensate Pump Room Flood Protection,

b. The rewritten LCO and Surveillance Requirements are taken from present technical specification provisions.

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$ c. The proposed Applicability is whenever the RHR service water or diesel generator cooling pumps are required to be operable.

d. Proposed Action 3.5.L.1 requires a vault that is not sealed and leaktight to be restored to operable in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or to declare the affected RHR service water or diesel generator cooling pumps inoperable.

e. Proposed Action 1.5.L.2 is based on present 3.5.H.2 and requires that viah one of the condenser pit water level trip

. circuits inoperable, action shall be taken within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and completed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to place the switch in trip. Seven days is then allowed to restore the switch to operable or the g sffected RHR service water or diesel generator cooling pumps shall be declared inoperable,

f. Proposed Action 3.5.L.3 addresses operability of the alarm circuits for the condensate Pump Room Flood Protection system.

Item 9 O

Pace 3.5/4.5-13. Soccification 3.5.I/4.5.I. DPR-29

a. Change the Specification number to 3.5.M/4.5.M for the Average Planar LHGR.

, b. The proposed LCO and Surveillance Requirements are taken from present requirements.

c. The proposed Applicability is Operational Mode 1, when Thermal Power is greater than or equal to 25% of Rated Thermal Power.

d. The proposed Actions modify present provisions by requiring g the plant to be taken to < 25% rated thermal power instead of to Cold Shutdown.

Item 10:

Eaga 3.5/4.5-13. Specification 3 5.J/4.5.]a, DPR-29 9 a. Change the Specification number to 3.5.N/4.5.N for the Local LHGR.

b. The proposed LCO and Surveillance Requirements are taken from present requirements.

g c. The proposed Applicability is Operational Mode 1, when Thermal Power is greater than or equal to 25% of Rated Thermal Power.

d. The proposed Actions modify present provisions by requiring the plant to be taken to < 25% rated thermal power instead of to Cold Shutdown.

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1 Eagt 3.5/4.5-14. Specification L.LEL4_ 5.K. DPR-29

a. Change the Specification number to 3.5.0/4.5.0 for the Minimum 9

Critical Power Ratio (MCPR).

b. The proposed LCO and Surveillance Requirements are taken from present requirements. .

c. The proposed Applicability is Operational Mode 1, when Thermal Power is greater than or equal to 25% of Rated Thermal Power.

O d. The proposed Actions modify present provisions by requiring the plant to be taken to < 25% rated thermal power instead of to Cold Shutdown.

Item 12t

] Paces 3.5/4.5-Lk through 3.5/4.5-27. DPR-29

a. Change titles and numbers of Bases sections to match changes to the technical specification sections described above.

b. Change Bases to describe the changes proposed in this amendment request.

c. Renumber new Bases pages.

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DESCRIPTION OF CHANGES b

PROPOSED TS 3.5/4.5 g ' CORE & CONTAINMENT COOLING SYSTEMS" D

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O O DESCRIPTION pr PROPOSED AMIFQMINI REQUEIT PROPOSED SPECIFICATION 3.5/4.5 CORE AND CONTAINMENT COOLING SYSTEMS O The changes pr posed in this amendment request are made to 1 improve the un erstanding and usability of the present techn cal specifications, 2) incorporate technical improvements, and 3) include some provisions from later operating BWR plants.

An item by item description of the proposed changes requested is O provided below. The Summary of Changes section can be referred to in order to reference back to a given change and its affected page.

GENERIC CllANGES O 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 O statement and provide Applicability statements within aach specification similar to the STS. The roposed A licabilit statement to be included in each specif cation wi include he Reactor Modes or other conditions for which the LCO must be satisfied.

Item 2 The changes proposed in this item will provide an STS type of format while retaining the present two column la out. The present format does not provide a separation of LCO, App icability and Action requirements that are easily understood and identifled.

The two column layout has been utilized at Quad Cities since

.n initial licensing of the plant and is preferred by the plant over v the single column STS layout.

Item 1 l This item provides the relocation of tne bases of the technical

( specifications from the present location of immediate'.y following

O 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. This change recognizes that the bases provide reference material which is of secondary l importance to the other material in the technical specifications.

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O SPECIFIC CHANGES Item 1 The proposed changes to Specification 3.5.A/4.5.A includes separatlon into two distinct specifications, 3.5.A/4.5.A for the o

Core Spray subsystem and 3.5.B/4.5.B for the LPCI Mode of the RHR System. This change will improve readability and improve the ability of the user to find requirements in the technical specifications. The proposed new Specifications apply only to plant operating conditions. Proposed Specification 3.5.H/4.5.H contains requirements for the Core Spray and RHR systems in Cold Shutdown and Refuel.

n The proposed LCO for the Core Spray subsystems implements present requirements by requiring both Core Fpray Subsystems to be operable in the Applicable Operational Modes. The present Applicable operational Modes for the Core Spray Subsystems is whenever irradiated fuel is in the reactor vessel and prior to reactor startup from a cold condition. The present Applicability u is proposed to be changed to operational Modes 1, 2, and 3 to match with present operability requirements of Operational Modes above the cold condition. This change provides consistency with the Operational hode Definitions provided in Table 1-2 and ensures operability of the affected systems when required to perform their design function. The proposed Actions for the Core Spray p#

Subsystems implement the provisions of present Specifications 3.5.A.2 and 3.5.A.6 with the exception of the reactor shutdown provisions and proposed Action 3.5.A.2. Tresent reactor shutdown provisions of 3.5.A.6 require initiation of an orderly reactor shutdown and the reactor to be in the cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The proposed change implements STS reactor shutdown provisions of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to Hot Shutdown and another 24 D hours to be in at least Cord Shutdown. The proposed reactor shutdown provisions require the plant to be in Hot Shutdown sooner than present provisions but allows an additional 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> over present provisions to reach Cold Shutdown. Proposed Action 3.5.A.2 adds restrictions not presently in the technical specifications in order to provide Action statements for the core spray header dp instrumentation. Proposed Action 3.5.A.2 is taken rU from STS guidelines which recognizes that header dp can be determined locally if the instrumentation channel is inoperabic, thus maintaining operability of the core spray subsystem. The proposed Action requires restoration of the inoperable header dp instrumentation channel within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the header dp must be determined locally once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If these remedial measures 3' are not met, the associated core spray subsystem is declared inoperable.

The proposed LCO for the LPCI Mode of the RHR System implements present provisions by requiring operability in the Applicable Operational Modes. The present Applicable operational Mod'es for the LPCI Mode of the RHR System is the same as for the Core Spray O Subsystems. Therefore, Applicable Operational Modes are proposed O

9 O to be Operational Modes 1, 2 and 3. The proposed Actions for the LPCI Mode of the RHR System kaplement the provisions of present Specifications 3.5.A.4 3 STS reactor shutdown t1me.5.A.5 and frames of 123.5.A.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> towith Hotthe exception Shutdown andof another 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to cold Shutdown as discussed above for the core Spray System.

O The proposed changes to Surveillance Requirement 4.5.A.1 will delete the monthly pump runs and change the monthly valve operability checks to require only monthly valve position verification checks. The quarterly pump flow tests performed in accordance with the Inservice Testing Program, per proposed Specification 4.0.E, are sufficient to demonstrate pump O operability and thus the present monthly pump runs can be deleted.

The present monthly valve operability checks can also be deleted as the valves are included and tested in accordance with the Quad Cities Inservice Testing Program. The monthly valve operability check is replaced with a monthly valve position verification check, a description of which is proposed to be added-to Bases-4.5. This valve position verification check is made on the O position of each manual, power operated or automatic valve in the flow path that is not locked, cealed, or otherwise secured in position. These proposed changeb reflect operating practices at later BWR plants and since the Quad Citieb ECCSs are similar to those at later plants, the proposed changes are justified and should be implemented.

Added to present SRs is pr posed SR 4.5.A.6 which requires a T-weekly verification that the doors on the pump compartments are closed for the core spray and LPCI Mode of RHR pumps. Proposed SR 4.5.A.G replacea present Specification 3.7.C.2/4.7.C.2

requirements and is more appropriately located in Section 4.5.

f) Present post-maintenance testing requirement 9 in Specification

4.5.A.1.b are deleted from the technical specifications since this type of testing is included in maintenance procedures and is already understood to be a part of the definition of system

Operability.

I,I Present testing terminology of Specification 4.5.A.1.e of check

' calibration and test for the Core Spray header dp instrumentatkon is not cons 1 stent with proposed changes to the_ definitions in Section 1.0. For consistency, these tests are changed to Channel Check, Channel Calibration and Channel Functional Test. present quarterly channel calibration tests for the core spray header dp instrumentation is changed to refueling in accordance with STS

Q guidelines. -The header dp instrumentation calibration records have been reviewed to ensure that the proposed change to refueling i test intervals is acceptable.

The proposed changes will delete present Surveillance Requirements 4.5.A.2, 4.5.A.4 and 4.5.A.5 which require:

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1. With one_ Core Spray System inoperable, immediately test the

O operable Core Spray Subsystem and the LPCI Mode of the RHR i

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3 System. The operable Core Spray Subsystem is then demonstrated operable daily thereafter.

2. With one of the RHR pumps inoperable, immediately test the remaining active components of the LPCI Mode of the RHR, 4 Containment Cooling Mode of the RHR and both Core Spray  !

3 Subsystems. The operable RHR pumps are tested daily thereafter.

3. With the LPCI Mode of the RHR System ino erable, immediately and daily thereafter demonstrate operabi ity of both Core l Spray Subsystems and the Containment Cooling Mode of the RHR. j J The present testing requirements for ECCS were chosen to be very l conservative at a time when there was a lack of plant operating history and a lack of a sufficient equipment failure data base to choose other testing methods. Over the years since initial development of the Quad cities Unit 1 and 2 technical specifications, plant operating experience has demonstrated that

, multiple testing of other ECCS systems when one system is J inoperable is not necessary to provide adequate assurance of system operability. Operability of these systems is shown by checking records to verify that valve lineups, electrical lineups and instrumentation requirements have not been changed since the last time that the system was verified to be operable. More recent BWR technical specifications accept system operability a

based on satisfactory performance of monthly, quarterly, refueling interval, post maintenance and other specified performance tests without requiring additional testing when another system is inoperable. One exception is diesel generator testing, but operating experience has shown that excessive testing of the diesel generators can adversely affect reliability. The purpose of this change is to remove excessive system testing requirements D while maintaining adequate assurance of system operability when needed for accident mitigation, one concern with equipment failures is common mode failure affecting the same parts in other systems. Engineering evaluation for common mode failure can be more effective than running systems and trying to find another failure of the same part. Once the potential for common mode

- failure has been identified, system operability is evaluated and J potentially defective parts are replaced or repaired.

Item 2 The proposed changes to Specification 3.5.B/4.5.B include, as in Item 1 above, splitting into two distinct specifications, 7' 3.5.C/4.5.C for the Containment Cooling Mode of RHR and 3.5.D/4.5.D for the Con 'inment Cooling Spray Loops. This change will improve the readabL 'ty of the specifications and the ability of the user to locate req irementa. The proposed new Specifications apply only to Plant Operating conditions, since the affected systems do not have operability requirements in Cold Shutdown or Refuel.

9 The proposed LCO for the Containment Cooling Mode of the RHR

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l O System implements present requirements by requiring two loops operable in the Applicable Operational Modes. The present Applicable Operational Modes for the containment Cooling Mode of the RHR System is whenever irradiated fuel is in the reactor vessel and prior to reactor startup from a cold condition. The proposed Applicability is Operational Modes 1, 2, and 3 which is O *9"iv"1 "t t requiredinalfresentrequirementssinceoperabilitywillbeOperational Modes except Cold S The proposed Actions for the containment Cooling Mode of the RHR System are taken from present requirements in 3.5.B.2, 3.5.B.3 and 3.5.B.5 with an exception taken to the present reactor shutdown provisions in 3.5.B.5. As described in Item 1 above, the reactor shutdown provisions are changed to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to Hot Shutdown and O another 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to Cold Shutdown. The proposed changes to Surveillance Requirement.4.5.B.1 for the RHR Service Water Subsystem involves deletion of the present quarterly pump and valve operability test and replacement with a monthly valve position check. The present quarterly pump flow rate test por the Inservice Testing program provides demonstration of pump operability and thus the deletion of the quarterly pump O operability test just eliminates unnecessary duplication of requirements in the technical specifications. The quarterly valve operability tests can be doloted from the technical specifications because the valves are included in the Quad Cities Inservice Testing Program. Monthly valve position verification checks are added to the technical specifications as in Item 1 above. As in O Item 1 above, post-maintenance testing requirements in present Specification 4.5.B.1.b are deleted and are properly implemented in maintenance procedures.

The proposed LCO Action and Surveillance Requirements for the Containment coollng Spray Loops implement present requirements with the exception of the addition of STS reactor shutdown O provisions in proposed Action 4.5.D.2. The proposed Applicability of Operational Modes 1, 2, and 3 implements present 5 9"ir*" "t*

for operability when the reactor is greater than 212 F and prior to reactor etartup from a cold condition.

The present one time exception of Specification 3.5.B.3.b to allow n

V sharing of Containment spray Loops betwoon Units 1 and 2 expired on November 1, 1989. The proposed change deletes this one time exception.

Present Surveillance Requirements 4.5.B.2 and 4.5.B.3 require testing of other RHR loops and equipment when one pump or loop is inoperable. The proposed change will delete these multiple O testing requirements using the justification presented in Item 1 above.

It2JD a The proposed changes for Item 3 involve the rewriting of present Specification 3.5.C/4.5.C into proposed Specification 3.5.E/4.5.E, titled HPCI Subsystem - Plant Operating. Changes were submitted O to the NRC on May 25, 1989, to revise the HPCI subsystem Technical 0

I D Specifications for Section 3.5.C/4.5.C. The proposed changes in this amendment request are based on the previously submitted amendment request and other necessan changes to provide consistency in presentation of material. The proposed LCO, Actions and Surveillances are based on material in the amendment request referenced above. The Applicability from the referenced D submittal is whenever the reactor pressure is greater than 150 psig and fuel is in the reactor vessel. The proposed Applicability of Operational Mode 1 and Operational Modes 2 and 3 whenever reactor pressure is greater than 150 psig is equivalent to the Applicability in the referenced submittal for plant operating conditions. The proposed Actions and Surveillance Requirements from the previous submittal are modified to delete p post-maintenance testing provisions since these provisions are adequately covered in maintenance procedures and are not needed in the Technical Specifications. The reactor shutdown provisions of proposed Action 3.5.E.3 are modified, in accordance with STS guidelines, from present provisions to allow 12 houts to reach Hot Shutdown and then another 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to be 5 150 psig. The proposed adoption of STS guidelines for reactor shutdown provisions will D require the plant to be in Hot Shutdown sooner than present provisions and will allow an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to be 5 150 psig.

over present provisions. Chanoen to the Bases that were proposed in the above referenced submit al are also included in this amendment request.

D The addition of proposed Specifications 4.0.D and 4.0.E require changes to proposed specification 4.5.E. The exception to allow entry into Operational Modos for testing will reference the provisions of Specification 4.0.D and the quarterly frequency for the HPCI pump flow rate test will reference the Inservice Testing provisions of Specification 4.0.E.

D Item 1 The proposed changes to present Specification 3.5.D/4.5.D include renumbering to proposed Specification 3.5.it/4.5.F, titled Automatic Pressure Relief Subsystems - Plant Operating. The proposed LCO requires all 5 of the Automatic Pressure Relief I Valves to be operable and clarifies present requirements which could be interpreted to allow one valve out of service at all times. The present Applicability is whenever the reactor pressure is greater than 90 psig, irradiated fuel is in the reac'.ar vessel and prior to startup from a cold condition. The proposed Applicability of Operational Mode 1 and Operational Modes 2 and 3 whenever reactor pressure is greater than 150 psig is based on p requiring the Subsystems to be operable in plant Operational Modes where reactor pressure is low enough to ensure sufficient overlap with the low pressure ECCS systems capability to inject water to the reactor vessel. This change to > 150 psig provides consistency with the operability requirements for HPCI and RCIC.

Proposed Actions are based on STS guidelines which require that with one of the required valves inoperable, 14 days is allowed for

> restoration of the valve provided the HPCI Subsystem, all active B

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O O components of both Core Spray subsystems, and thn LPCI Mode of the RHR System are operable. If these remedial Action provisions are not met, the plant is required to be in at least Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to reduce reactor vessel pressure to 5 150 psig within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. With two or more of the required valves inoperable, the plant is required to be in at >

() least Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to reduce reactor vessel pressure to 5 150 psig within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The proposed Actions adequately cover all potential operability concerns and ensure that adequate core cooling systems are available when the operability of the automatic pressure relief valves is degraded.

The proposed changes to the Surveillance Requirements deletes O present Specification 4.5.D.4 which requires testing of the HPCI wh?never two valves of the Automatic Pressure Relief Subsystem are inoperable. The justification for deletion of the multiple system testing provisions is provided in the Item 1 discussion above.

The proposed changes add a needed exception to the provisions of proposed Specification 4.0.D to allow entry into Operational Modes to allow testing to demonstrate operability of the relief valves.

O Present SR 4.5.D.1 requires a six-month frequency for testing the automatic pressure relief valves by manually opening each valve and verifying the opening by a compensating turbine bypass valve or control valve closure. The present six-month testing frequency was placed in the Quad Cities Technical Specifications by

'O Amendments 40 and 38, dated May 2, 1977, for Units 1 and 2, respectively. As described in the Safety Evaluation for these amendments, the NRC staff concluded that the surveillance -

frequency at Quad Cities Station should be increased from once per operating cycle to once per six months. The NRC Staff determined that the increased testing frequency was necessary to assure early detection of relief valve (RV) malfunctions that were occurring

() more frequently at Quad Cities Staticn than at any other nuclear power station. Frequent Electromatic Relief Valve (ERV) malfunctions had occurred prior to issuance of these amendments and continued to occur during 1977, 1978, 1980 1981 and 1982.

For the most part, relief valve malfunctions we,re dis, covered during the semi-annual surveillance. Partly due to the increased frequency of testing the relief valve problems

() appeared to increase, initially,ifferent

. Several d types of failures were attributable to several different causes. Appropriate generic corrective actions were taken for RVs as different failure modes were discovered. During 1977, there were three failures of RVs to operate during testing due to a loose disc retainer plug locking arm which allowed steam to leak below the valve disc preventing Q- proper valve operation. Vibration caused the loosening of the locking arms. The locking arms on the ERVs were subsequently replaced with seal welds. During 1978 and 1981, the same RV failed to open during testing due to the main disc rings on the RV wearing a circumferential groove into the disc guide sleeve, ,

locking the valve in the closed position. Contributing to the failure was the high vibration associated with the RV location O (3E) . After replacing the valve in 1981, a maintenance program

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O O was initiated to ins Also, during a semi pect annual thesurveillance "3E" RV every refueling in 1978, a RVoutage.

failed to ,

open due to broken welds between the valve body and cage. This combined with vibration caused the piston rings to wear into the disc guide, restricting smooth movement of the disc. As corrective action, modifications were performed on all ERVs - the O cage was welded to the valve body to reduce wear on internal parts caused by vibration. During 1980, several different solenoid valve problems (e.g., excessive solenoid-to-pilot valve stem clearance, dirty contacts, were discovered during semi-annual testing. pilot valve leakage)

Solenoid valve seat leakage problems (5 valves) resurfaced again in 1984 during routine maintenance.

These failures were attributed to cyclic fatigue and the entire O pilot valves on ERva were replaced. ouad-cities began replacing all RV pilots during each refueling outage to minimize this problem as being a mode of RV failure. During 1982, a RV failed to open following a scram due to binding of valve plug compression rings caused by a groove in the sleeve. This was apparently due to high vibration and the sleeve material being below the hardness recommended by the manufacturer. The valve sleeves on the RVs O were replaced at the next refueling outages following this failure. ERV malfunctions have decreased significantly sincn 1984 as a recult of the many modifications made to resolve generic design problems and the implementation of improved maintenance programs for these valves. Looking at LER data to date, from 1973 through 1984, 37 LERs were written on the ERVs on both Quad cities

'O Units 1 and 2. From 1984 to present, only 1 LER due to a ERV failure was recorded. Routine maintenance and inspection of the ADS valves is performed every refueling outage. All Automatic Pressure Relief Valve pilot valves are replaced every cycle. All Automatic Pressure Relief Valves are replaced overy two cycles except for the valve in the "3E" location which is replaced every cycle due to vibration problems as discussed above. Based on this O performance record since 1984, Commonwealth Edison believes that an extension to the surveillance testing interval from 6 months to the STS guideline of 18 months is justified.

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.g The proposed changes for Item 5 include the rewrite of present Specification 3.5.E/4.5.E into proposed Specification 3.5.G/4.5.G, titled Reactor Core Isolation Cooling System - Plant Operating.

Changes were submitted to the NRC on May 25, 1989, to revise the RCIC Subsystem Technical Specifications for present Section 3.5.E/4.5.E. The proposed changes in this amendment request are based on the previously submitted amendment request and other

<3 necessary changes to provide consistency in presentation of material. The proposed LCO, Actions and Surveillances are based on material in the amendment request referenced above. The Applicability from the present specification is whenever the reactor pressure is greater than 150 poig and fuel is in the reactor vessel. The proposed Applicability of operational Mode 1 and operational Modes 2 and 3 whenever reactor pressure is greater O than 150 psig is equivalent to the present Applicability for plant l

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. l 0 operating conditions and clarifies the intent contained in the previous amendment request discussed above. Post-maintenance testing requirements contained in Action 3.5.E.2 of the previous ,

amendment request is deleted, since this type of testing is adequately covered in maintenance procedures and is not needed in the technical specifications. Proposed Action 3.5.G.3 contains  :'

reactor shutdown provisions based on STS guidelines. Reactor

'O shutdown provisions in the previous amendment request require an orderly shutdown be initiated and reactor pressure to be reduced to < 150 psig within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This change to STS reactor shutdown provisions will require the plant to be in Hot Shutdown sooner than present provisions and will a3 tow another 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to l' be <150 psig. The proposed exception in Eurveillance Requirement

~O 4.5.E to the provisions of Specification 4.0.D is needed to allow entry into operational Modes to accomplish RCIC testing.

Item i The pro osed changes to= Specification 3.5.F/4.5.F include separat on into two distinct specifications, 3.5.H/4.5.H for the I)- Plant Minimum Shutdown and Corenew and3.5.I/4.5.I Containmant forCooling Suppression SystemChamber Availability Requirements for Core and Containment Cooling Systems.

Present Specification 3.5.F.2 allows all low pressure core and ,

containment cooling systems to be inoperable while in cold

'o shutdown provided no work is being done which has the potential for draining the reactor vessel. The resent re uirements do not

-address-specific ECCS-operability requ rements d ring cold shutdown or refueling conditions. The proposed change will rewrite present Specification 3.5.F.2 using STS guidelines and

-replace it with more prescriptive requirements for ECCS operability during cold shutdown and refueling. The proposed O Specification will be applicable when the reactor is in cold shutdown or-refuel conditions, Operational Modes 4 and 5, and will require at least two pumps of low pressure ECCS to be operable along with an operable flow path for each pump taking suction from the suppression pool or the condensate storage tank and transferring water to the reac'or vessel. These pumps can be two 1 w pressure _ core spray pumps, two low pressure coolant injection

'O ump or a core spray pum and a LPCI pump. Proposed-LCO 3.5.H ss ilar to present Spec fication 3.5.F.2 in that all low pressure core and containment cooling subsystems are allowed to be inoperable with certain limitations in the refuel condition.

These limitations include the restrictions of having the reactor vessel head removed, the cavity flooded, the spent fuel pool gates

-Q - removed, fuel pool water level maintained above the low level

-alarm point and the reactor cavity water temperature below 140 ,

degrees F. These additional restrictions apply to the refuel condition only, and ensure that the reactor head is removed and a large volume of water is available in the reactor cavity and spent fuel areas before all low pressure core and containment cooling subsystems can be made inoperable. The proposed suppression

1) chamber water level allowance of at least 7 feet above the bottom l

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D D of the suppression chamber takes into consideration pump suction head, vortex requirements and temperature limits to ensure that necessary pump operability ir maintained.

The changes sre being proposed in order to provide specific operability requirements for low pressure ECCS systems while the g reactor is in cold shutdown and refueling conditions. Present Quad Cities technical specifications require LPCI and both Core Spray subsystems to be operable whenever irradiated fuel is in the reactor vessel and prior to reactor startup from a cold condition with an exception being that all the subsystems may be inoperable in cold shutdown provided no work is being done whlch has the potential for draining the reactor vessel. Also Containment

> Cooling is required whenever irradiated fuel is kn the reactor vessel and prior to reactor startup from a cold condition with the same exception as for the LPCI and Core Spray nubsystems while in cold shutdown. Since the primary system is not pressurized in cold shutdown or refuel, the ECCS water makeup requirements are significantly less than for the conditions of reactor power operation or hot shutdown. Propcssd Specification 3.5.H requires I at least two pumps of the low pr essure ECCS to be operable, with each having an operable fic- path capatle of taking suction from the suppression pool or the cormenaste storage tank and transferring the water to the 1asntsr vessel, when the reactor is in cold shutdown or refuel conditivns. The proposed requirements follow Standard Plant Lnu later UWR operating plant requirements p for ECCS systems during these modes of operation.

Proposed Action i foc Specification 3.5 H will not allow operations with a potential for drainir.g the reactor vessel to continue if one of _ht required pumps and/or associated flow paths of ECCS is inoperabic for more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The four hour requirement allows & reasonable time frame to restore the

> inoperablu comp;nents or to enke another pump and/or associated flow path operable. The four hour requirement also is of sufficiently 4hert duration such that the probability is very small that an accident that results in draining the reactor will occur in this squipment out of service period.

I Propoead action 2 for Specification 3.5.H applias if both of the required ECCS pumps and/or flow paths are inoperable. With both of the ECCS pumps and/or f low paths inoperable, core alterations and all operations with a potential for draining the reactor vessel are suspended. At least one of the required ECCS pumps and associated flow paths must be returned to operable status within four hours or secondar p

with the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.y containment The four hourintcgrity must allowance be established provides a reasonable time frame to restore the inoperable components or to make another pump and/or associated flow path operable. The eight hour time requirement for establishing secondary containment integrity allows a reasonable time for closing up and testing the seconda- containment boundary.

O O Present Specifications 3.5.r.3 and 3.5.r.4 contain requirements for the operability of the suppression chamber when irradiated fuel is in the reactor and the reactor vessel head is removed.

These requirementa cre proposed to be replaced as Specificationu 3.5.I/4.5.I ustP.f $5a guidelines and some present provisions.

Proposed LCO l(k 3,? o 3Ruires the Suppression Chamber to be O perable in op< rut e rn4 vedes 1, 2, and 3 with a contained water volume corresf ot,d Pd De A* 1 east 14'-1" above the bottom of the suppression eftpaNd 7 09 present requirement of 112,200 ft 3 is changed to 14t<1? (MO'y (Se bottom of the suppression chamber to provide an equivag(ho tuguirsment which is referenced from a permanent plant reference. the addition of Operational Modes 1, 2, and 3 are intended to match Core and Containment Cooling System 0 operability requirements with Suppression Chamber operability requirements. Proposed LCO 3.5.I.2 is.taken from STS provisions and addresses Suppression Chamber requirements in Operational Modes 4 and 5. Conditions imposed in LCO 3.5.1.2 to allow the Suppression Chamber level to be less than the limit or drained are that no operations are performed that have a potential to drain the reactor, the mode switch is locked in the Shutdown or Refuel O position, the CST contains at least 230,000 gallons of water and the core cooling systems operability requirements of 3.5 H.1 are ,

met. Proposed LCO 3.5.I.3 allows the Suppression Chamber to be

. inoperable in operational Mode 5 provided that the reactor head is removed, the reactor cavity is flooded, the fuel storage pool gates are removed, the fuel storage pool water level is maintained 9 above the low level alarm point, and the reactor cavity water temperature is below 140 degrees F. These additional restrictions imposed on proposed LCos 3.5.I.2 and 3.5.I.3 provide assurance that adequate provisions are in place to allow the Suppression Chamber to be drained or inoperable in Operational Modes 4 or 5.

The proposed Actions for Specification 3.5.I utilize STS O guidelines to ensure that the Suppression Chamber is available when required or that steps are taken to place the plant in Cold Shutdown or to suspend operations that have a potential to drain the reactor while in Modes 4 or 5. While in Modes 4 or 5, further Action steps will require that the reactor mode switch be locked in the Shutdown position and that Secondary Containment Integrity be established if the conditions of the LCO cannot be met.

O New Surveillance Requirements 4.5.I.1 and 4.5.I.2 help to ensure operability of the Suppression Chamber. Suppression Chamber water level is presentl so this additior, y to being the monitored and recorded on technical specifications does a daily not basis, represent any new requirements being added to the plant o surveillance testing program. The addition of 4.5.I.2 helps to ensure the conditions of the LCO are being met in operational Modes 4 or 5 with the Suppression Chamber less than the limit or drained.

Present Specification 3.5.F.1 states that any combination of inoperable components in the Core and Containment Cooling Systems

.O shall not defeat the capability of the remaining operable O

B D components to fulfill the Core and Containment Cooling functions.

This present requirement is ambiguous and does not provide definitive operability statements. This present requirement is being replaced with rewritten spacifications for the Core and Containment Cooling Systems, Suppression Chamber and Minimum Core and containment Cooling System Availability. These new g specifications contain definitive operability requirements for the systems affected and thus Specification 3.5.F.1 can be deleted.

Item 2 The proposed changes for Item 7 include the rewrite of present Specification 3.5.G/4.5.G into two distinct Specifications, h

3.5.J/4.5.J for Maint2 nance of Filled Discharge Pipe for Core

Spray,ication Specif 3.5.H;LPCI Mode of RHR and the RHR and Specification loops usedfor 3.5.K/4.5.K to satisfy Maintenance 4

of Filled Discharge Pipe for RCIC and HPCI.

The proposed LCO, Applicability and Surveillanco Requirements for new Specification 3.5.J/4.5.J are taken from present requirements.

8 The proposed Actions are taken frtm present requiremtnts with some modifications. Present Specification 3.5.G.2 requires that with discharge pipe pressure not within limits that this condition shall be alarmed in the control room and immediate corrective action taken. The use of the term "immediate" is not definitive and has been replaced with the term of one hour. Present D Specification 3.5.G.2 also requires that with the discharge pipe pressure not within limits in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the occurrence, an orderly shutdown shall be initiated and the reactor shall be in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after initiation. The requirement to shut the plant down has been replaced with a requirement to declare the affected system (s) inoperable and to take the appropriate system actions. This action is more D appropriate than shutting down the plant since pipe discharge pressure directly affects system operability and the technical specifications for the affected systems contain appropriate actions to be taken if the system is inoperable. Proposed Action 3.5.J.1 is taken from STS guidelines to address the condition when a discharge line keep filled pressure alarm instrumentation channel is inoperable. With a channel inoperable, Action 3.5.J.1 k will require that the system be vented at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Present Specification 3.5.G/4.5.G contains both an upper and lo*.cr limit, 40 and 90 psig, on the fill system pressure for the Core Spray and RHR systems. Present Bases 4.5 describes the reasons for having both an upper and lower pressure limit. The lower p limit of 40 psig was chosen to account for piping elevations to ensure that the lines are full of water. The upper limit of 90 psig is greater than the shutoff head of the fill pumps and less than the low pressure cooling pump discharge pressure interlock for ADS initiation of 100 psig. The pressure tap for the ADS interlock is located between the low pressure cooling pump and the pump discharge check valve. The fill system pumps inject water D downstream of the pump discharge check valve and thus the pressure B

O 33 of the fill system is not seen by the ADS pressure sensing lines.

The upper limit of 90 psig is not needed to provide margin to the ADS low pressure pump discharge pressure interlock and is thus deleted.

The proposed LCO and Applicability for new Specification 3.5.K are

'o taken from present requirements.

implements present requirements if the CCST level falls below 9.5 Proposed Action 3.5.K.1 feet by restoring the level within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or lining up the HPCI or RCIC to take suction from the suppression chamber. Proposed Action 3.5.K.2 requires the HPCI and/or RCIC system (s) to be declared inoperable and appropriate system actions taken if the provisions of Action 3.5.K.1 are not met. This action requirement

() is appropriate in referencing the affected system for action provisions since system operability is affected by inoperability of the discharge pipe fill provisions. Proposed Surveillance Requirement 4.5.K.2 is taken from present provisions while 4.5.K.1 is a new requirement. Proposed Surveillance Requirement 4.5.K.1 requires the water level in the CCST's to be verified to be 2 9.5 C) feet at least once per day when the HPCI and/or RCIC systems are lined up to take suction from the CCST's. This new provision is being added to the Technical Specifications to ensure verification that the conditions of the LCO are being met. The level of the CCST's is currently being verified each shift during shift turnover and as such this change does not represent any new testing being added to the plant.

O ltren a The Specifications for the Condensate Pump Room Flood Protection are renumbered to 3.5.L/4.5.L in order to implement changes discussed above. The LCO and Surveillance Requirements for new Specification 3.5.L

.O The proposed Applica/4.5.L are taken from present requirements.bility is whenever the RH diesel generator cooling pumps are required to be operable. The new Applicability statement is based on requiring the condensate Pump Room Flood Protection to be operable when equipment in the rooms is required to be operable.

O Present Specification 3.5.H.2 contains requirements if there is a failure in one of the trip and alarm circuits. The failed circuit

-is required to be placed in trip immediately and reactor operation is permissible for the following 7 days and then by present Specification 3.5.H.3 reactor startup is not allowed or if i

operating an orderly shutdown shall be initiated. Proposed changes to the present Actions will add new Action 3.5.L.1 to O provide requirements if one or more of the vaults is not sealed or i

leaktight. The addition of 3.5.L.1 will ensure that appropriate Action is taken and that affected systems are declared inoperable in a reasonable time frame. New Actions 3.5.L.2 and 3.5.L.3 are added to provide separate requirements for the trip and alarm

! circuits of the Condensate Pump Room Flood Protection system.

Operability of the trip circuits is more important than that of l$) the alarm circuits and as such separate action provisions are made l

l l

l O

l

O O to highlight these differences. With one of the trip circuits inoperable, action is required to be initiated within one hour and completed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to place the failed trip circuit in a tripped condition. If the trip circuit is not restored within 7 days, then the affected system s) is declared inoperable and appropriate system actions are(taken. New Action 3.5.L.3 for the q

Alarm circuits requires a special report to be prepared and submitted to Commission if all the alarm circuits are inoperable for more than 30 days. This provision will ensure that the alarm circuits are addressed in the Technical Specifications and that operability will be maintained in a reasonable fashion.

Items L 1h and n O

The present Specification numbers are changed to reflect the changes discussed in the items above. Average Planar LHGR is 3.5.M Ratio /4.5.M, Local LHGR is 3.5.N/4.5.H is 3.5.0/4.5.0. Proposed and LCOsMinimum Critical Power and Surveillance Require (MCPR) ments are taken from present provisions for all three Specifications. Proposed Applicability is operational Mode 1, O when Thermal Power is greater than or equal to 25% of Rated Thermal Power. This proposed Applicability provides consistency with the present Surveillar~c Requirements which are required to be performed ouring steady state operation above 25% Rated Thermal Power. The changes proposed to the present Action provisions will require a reduction to < 25% power instead of the present g' requirement to go to Cold Shutdown in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This change in the Action provisions provides consistency with present surveillance requirements and proposed operability requirements.

Itca 12 The changes proposed to the Bases for Section 3.5/4.5 are made in e order to implement the changes proposed in the items above. The additions made to the Bases will help to clarify the meaning of

" verification" of system operability when one system is inoperable and explain some of the changes proposed to present requirements.

4 O

D D

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