ML20085H030

Safety Evaluation Supporting Amends 134,128,155 & 151 to Licenses DPR-19,DPR-25,DPR-29 & DPR-30,respectively

ML20085H030
Person / Time
Site:	Dresden, Quad Cities
Issue date:	06/13/1995
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20085H017	List: ML20085H012 ML20085H030
References
NUDOCS 9506200451
Download: ML20085H030 (22)

Text

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y UNITED STATES

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NUCLEAR REGULATORY COMMISSION

~f WASHINGTON. D.C. 30666-0001

.... 4 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATf9 TO AMENDMENT NO.134 TO FACILITY OPERATING LICENSE NO. DPR-19.

AMENDMENT NO.128 TO FACILITY OPERATING LICENSE NO. DPR-25.

AMENDMENT NO.155 TO FACILITY OPERATING LICENSE NO. DPR-292 AND AMENDMENT N0.151 TO FACILITY OPERATING LICENSE NO. DPR-30 COMMONWEALTH EDISON COMPANY SE IOWA-ILLIN0IS GAS AND ELECTRIC COMPANY DRESDEN NUCLEAR POWER STATION. UNITS 2 AND 3 OVAD CITIES NUCLEAR POWER STATION. UNITS 1 AND 2 DOCKET NOS. 50-237. 50-249. 50-254 AND 50-265

1.0 INTRODUCTION

By letter dated September 15, 1992, as supplemented by letter dated April 21, 1995, Commonwealth Edison Company (Comed, the licensee) submitted an amendment requesting to upgrade sections of the Dresden Nuclear Power Station, Units 2 and 3, and the Quad Cities Nuclear Power Station, Units 1 and 2, Technical Specifications (TS). The changes have been requested as part of their Technical Specification Upgrade Program (TSUP),

As a result of findings by a Diagnostic Evaluation Team inspection performed by the NRC staff at the Dresden Nuclear Power Station in 1987, Comed made a decision that both the Dresden Nuclear Power Station and sister site Quad Cities Nuclear Power Station, needed attention focosed on the existing custom TS used at the sites.

The licensee made the decision to initiate a TSUP for both Dresden and Quad Cities. The licensee evaluated the current TS for both stations against the Standard Technical Specifications (STS), contained in NUREG-0123, " Standard Technical Specifications General Electric Plants BWR/4, Revision 4."

Both Dresden and Quad Cities are BWR-3 designs and are nearly identical plants.

The licensee's evaluation identified numerous potential improvements such as clarifying requirements, changing the TS to make them more understandable and to eliminate the need for interpretation, and deleting requirements that are no longer considered current with industry practice. As a result of the evaluation, Comed elected to upgrade both the Dresden and Quad Cities TS to the STS contained in NUREG-0123.

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The TSUP for Dresden and Quad Cities is not a complete adaption of the STS.

The TSUP focuses on (1) integrating additional information such as equipment operability requirements during shutdown conditions, (2) clarifying requirements such as limiting conditions for operations and action statements utilizing STS terminology, (3) deleting superseded requirements and modifications to the TS based on the licensee's responses to Generic Letters (GL), and (4) relocating specific items to more appropriate TS locations.

The application dated September 15, 1992, as supplemented April 21, 1995, proposed to upgrade only those sections of the TS to be included in TSUP Sections 2.0 (Safety Limit and Limiting Safety System Settings), 3/4.11 (Power Distribution Limits), and 3/4.12 (Special Test Exemptions) of the Dresden and Quad Cities TS.

The staff reviewed the proposed changes and evaluated all deviations and changes between the proposed TS, the STS, and the current TS.

In no case did the licensee propose a change in the TS that would result in the relaxation of the current design requirements as stated in the Updated Final Safety Analysis Reports (UFSAR) for Dresden or Quad Cities.

In response to the staff's recommendations, the licensee submitted identical TS for Quad Cities and Dresden except for plant-specific equipment and design differences. Technical differences between the units are identified as appropriate in the proposed amendment.

2.0 EVALUATION Review Guidelines - The licensee's purpose for the TSUP was to reformat the existing Dresden and Quad Cities TS into the easier to use STS format.

Plant specific data, values, parameters, and equipment specific operational requirements contained in the current TS for Dresden and Quad Cities were retained by the licensee in the TSUP.

The STS contained in NUREG-0123 were developed by the NRC and industry because of the shortcomings associated with the custom TS which were issued to plants licensed in early 1970's (i.e., Dresden (1971) and Quad Cities (1972)). The STS developed by the NRC and industry provided an adequate level of protection for plant operation by assuring required systems are operable and have been proven to be able to perform their intended functions. The limiting conditions for operation (LCO), the allowed out-of-service times, and the required surveillance frequencies were developed based on industry operating experience, equipment performance, and probabilistic risk assessment analysis during the 1970's. The STS were used as the licensing basis for plants licensed starting in the late 1970's.

Fnr the most part, Comed's adoption of the STS resulted in more restrictive LCOs and surveillance requirements (SR).

In some cases, however, the STS provides relief from the Dresden and Quad Cities current TS requirements.

In all these cases, the adoption of the STS requirements for LCOs or SR does not change the current design requirements of either plant as described in each

plant's UFSAR.

In addition, the success criteria for the availability and operability of all required systems contained in the current TS are maintained by the adoption of the STS requirements in the proposed TSUP TS.

In addition to adopting the STS guidelines and requirements in the TSUP, Comed has also evaluated Generic Letters (GLs) concerning line item improvements for TS. These GLs were factored into TSUP to make the proposed TS in the TSUP reflect industry lessons learned in the 1980's and early 1990's.

Deviations between the proposed specifications, the STS, and the current TS were reviewed by the staff to determine if they were due to plant specific features or if they posed a technical deviation from the STS guidelines.

Plant specific data, values, parameters, and equipment specific operational requirements contained in the current TS for Dresden and Quad Cities were retained by the licensee in the upgraded TS.

Administrative Chances - Non-technical, administrative changes were intended to incorporate human factor principles into the form and structure of the STS j

so that they would be easier for plant operation's personnel to use.

These j

changes are editorial in nature or involve the reorganization or reformatting of requirements without affecting technical content of the current TS or operational requirements.

Every section of the proposed TS reflects this type I

of change.

More Restrictive Reauirements - The proposed TSUP TS include certain more restrictive requirements than are contained in the existing TS.

Examples of more restrictive requirements include the following:

placing an LC0 on plant equipment which is not required by the present TS to be operable; adding more restrictive requirements to restore inoperable equipment; and adding more l

restrictive SR.

Less Restrictive Reauirements - The licensee provided a justification for less restrictive requirements on a case-by-case basis as discussed in this SE.

I When requirements have been shown to provide little or no safety benefit, their removal from the TS may be appropriate.

In most cases, these relaxations had previously been granted to individual plants on a plant-specific basis as the result of (a) generic NRC actions, and (b) new NRC staff positions that have evolved from technological advancements and operating experience.

The Dresden and Quad Cities plant designs were reviewed to determine if the I

specific design basis was consistent with the STS contained in NUREG-0123.

All changes to the current TS and deviations between the licensee's proposed TS and the STS were reviewed by the staff for acceptability to determine if l

adequate justification was provided (i.e., plant specific features, retention of existing operating values, etc.).

l Deviations the staff finds acceptable include:

(1) adding clarifying statements, (2) incorporating changes based on GLs, (3) reformatting multiple steps included under STS action statements into single steps with unique I

identifiers, (4) retaining plant specific steps, parameters, or values, (5) moving ACTION statements within a TS, (6) moving ACTION statements from an existing TS to form a new TS section, and (7) omitting the inclusion of STS steps that are not in existing TS.

Relocation of Technical Soecifications - The proposed TS include the i

relocation of some requirements from the TS to licensee-controlled documents.

Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to state Technical Specifications to be included as part of the license. The Commission's regulatory requirements related to the i

content of TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items.in five specific categories, including (1) safety limits, j

limiting safety system settings, and limiting control settings; (2).11miting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TS.

The Commission has provided guidance for the contents of TS in its " Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors, 58 Fed. Reg. 39132 (July 22,1993), in which the Commission indicated that. compliance with the Final Policy Statement satisfies Section 182a of the Energy Reorganization Act. The Final Policy Statement identified four criteria to be used in determining whether a particular uatter is required to be included in the TS, as follows:

(1) Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product-barrier; (3) a structure, system, or component that is part of a primary l

success path and which functions or actuates to mitigate a Design Basis Accident of Transient that either assumes the failure of or presents a j

challenge to the integrity of a fission product barrier; (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety. As a result, existing TS requirements which fall within or satisfy any of the criteria in the Final Policy Statement must be retained in the TS, while those l

TS requirements which do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.

The following sections provide the staff's evaluations of the specific proposed TS changes.

l 3.0 EVALUATION OF TSUP PROPOSED TS SECTION 2.0 SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS The following sections provide the staff's evaluation of the TS changes l

i reflected in proposed TSUP TS Section 2.0.

Proposed TSUP TS Section 2.0 results from combining current TS Sections 1/2.1 and 1/2.2 and reformatting to STS format. Section 2.0 establishes operating parameters to assure specific I

[

• acceptable fuel design limits are not exceeded during steady state operation, normal operational transients and anticipated operational occurrences.

3.1 Section 2.1.A: THERMAL POWER. Low Pressure or low Flow Proposed TS 2.1.A, "TERMAl POWER, Low Pressure or Low Flow," incorporates the requirements of the FTS Section 2.1.1 and current TS requirements from Section 1.1.B of the current TS for both stations. The proposed section has been reformatted adopting the STS guidelines.

Plant specific values for the listed parameters are included to be consistent to the UFSAR for both stations. The current TS do not contain specific applicability requirements or required actions. Specific applicability statements in accordance with STS guidelines have been adopted in the proposed TS.

In addition, required actions have been adopted in the proposed TS in accordance with STS guidelines when the safety limit is violated. There are no changes and/or deviations from STS guidance in the proposed TS Section.

A change to current TS Section 1.1.B. for both Dresden and Quad Cities Stations has been proposed.

The Reactor Vessel Steam Space Pressure which defines the transition between high and low pressure for this safety limit in the current TS is 800 psig, while in the proposed TS it is 785 psig. The 800 psig is an incorrect value for the safety limit.

The current specifications for both Dresden and Quad Cities contain an error, using both 800 psig and 800 psia values for this set point. The current TS LCOs use 800 psig wale the Bases use 800 psia. The 800 psia value is the correct value.

To be consistent with STS guidelines, the proposed TS will express pressures in units of psig. The UFSAR and the Core Operating Limits Reports for Dresden and Quad Cities both use the value of 785 psig which is equivalent to 800 psia. The proposed TS is consistent with the UFSARs and design requirements for both stations and is also consistent with the guidance of the STS.

Based on the above evaluation, the staff finds that the proposed TS 2.1.A:

THERMAL POWER, Low Pressure or Low Flow has been reformatted adopting the STS guidelines. The staff has reviewed the proposed TS against the STS and current TS requirements and finds that there are no deviations from STS guidelines and the proposed TS have incorporated the current TS requirements for this safety limit.

In addition, the staff finds the change to the current pressure transition point is consistent with the current plants UFSAR and is, therefore, acceptable. Therefore, the staff finds that proposed TSUP TS 2.1.A:

" THERMAL POWER, Low Pressure or low Flow" is acceptable.

3.2 Section 2.1.B: THERMAL POWER. Hiah Pressure and Hiah Flow Proposed TS 2.1.B, " THERMAL POWER, High Pressure and High Flow," incorporates the requirements of the STS Section 2.1.2 and current TS Section 1.1. A. for both stations.

Plant specific values for the listed parameters are included

?.o be consistent to the UFSAR for the plants. The current TS do not contain specific required action or applicability statements for this specific safety limit. The proposed TS incorporates actions and applicability statements in accordance with the STS guidelines and format.

A change to current TS Section 1.1.A for both Dresden and Quad Cities Stations has been proposed.

The Reactor Vessel Steam Space Pressure which defines the transition between high and low pressure for this safety limit in the current TS is 800 psig, while in the proposed TS it is 785 psig. The 800 psig is an incorrect value for the safety limit. The current specifications for both Dresden and Quad Cities contain an error, using both 800 psig and 800 psia values for this set point. The current TS LCOs use 800 psig while the Bases use 800 psia. The 800 psia value is the correct value. To be consistent with STS guidelines, the proposed TS will express pressures in units of psig.

The UFSAR and the Core Operating Limits Reports for Dresden and Quad Cities both use the value of 785 psig which is equivalent to 800 psia. The proposed TS is consistent with the UFSARs and design requirements for both stations and is also consistent with the guidance of the STS.

The proposed TS conservatively maintains the 0.01 adder for the Minimum Critical Power Ratio (MCPR) limit when in Single Loop Operation to accoun'. ter increased uncertainties in the core flow and neutron flux monitoring measurements. This is a deviation from STS guidance, but is consistent with current TS requirements and is consistent with the guidance provided in GL 86-09, " Technical Resolution of Generic Issue No. B (N-1) Loop Operation in BWRs and PWRs."

Based on the above evaluation, the staff finds that the proposed TS for Section 2.1.B:

" THERMAL POWER, High Pressure and High Flow" has been reformatted adopting the STS guidelines. The staff has reviewed the proposed TS against the STS and current TS requirements and finds that the deviation from STS is acceptable and that all existing TS requirements have been incorporated into the proposed TS for this safety limit.

In addition, the staff finds that the change to the current pressure transition point is consistent with the current plant designs as described in the UFSARs and is, therefore, acceptable. The staff finds that the proposed TSUP TS Section 2.1.B:

" THERMAL POWER, High Pressure and High Flow" is acceptable.

i 3.3 Section 2.1.C:

Reactor Coolant System Pressure Proposed TS Section 2.1.C, " Reactor Coolant System Pressure," incorporates the requirements of STS Section 2.1.3, and current TS Section 1.2 for Dresden and current TS Section 1.2.A. for Quad Cities.

Plant specific values for the safety limit are included to be consistent with the UFSAR for the plants. The current TS do not have specific required action or applicability statements for this specific safety limit.

Proposed actions and applicability statements have been incorporated into the proposed TS in accordance with STS guidelines and format. There are no changes and/or deviations from STS guidance in the proposed TS and the proposed TS have incorporated all the current TS requirements concerning this safety limit.

The current TS for Quad Cities states that compliance with the safety limit for the Reactor Coolant System Pressure is measured in the reactor vessel steam space.

In the proposed TS, the licensee has adopted the STS nomenclature and indicates that compliance with the safety limit shall be

measured in the reactor vessel steam dome. The instrumentation used to verify compliance has not changed from the current TS to the proposed TS and, therefore, the staff finds that the proposed nomenclature change from steam space to steam dome to match STS guidelines is acceptable.

The proposed TS changes are administrative in nature and, therefore, do not reduce the margin of safety for Dresden or Quad Cities Stations.

The staff finds that the proposed TS 2.1.C:

" Reactor Coolant System Pressure" has been reformatted adopting the STS guidelines.

The staff has reviewed the proposed TS against the STS and current TS requirements and finds that the proposed TS do not deviate from STS guidelines and do not relax any existing TS requirements. Therefore, the staff finds the proposed TSUP TS Section 2.1.C, " Reactor Coolant System Pressure" acceptable.

3.4 Section 2.1.D:

Reactor Vessel Water Level Proposed TS Section 2.1.0, " Reactor Vessel Water Level" incorporates the requirements of STS Section 2.1.4 and current TS Section 1.1.0 for both stations. Plant specific values for the listed parameters are included in the proposed TS to be consistent to the UFSAR for the plants.

The current TS do not contain specific required action or applicability requirements.

Proposed actions and applicability statements have been incorporated into the proposed TS in accordance with the STS guidelines and format. The proposed TS have incorporated all the current TS requirements concerning this safety limit.

The proposed TS conservatively specifies the Reactor Vessel Water Level Safety Limit as greater than or equal to twelve inches above top of active fuel (TAF). STS Section 2.1.4 only specifies TAF.

The proposed TS maintains the current TS value and is consistent with the UFSAR which provides a point which can be adequately monitored and provides adequate margin for effective action.

The staff, therefore, finds the deviation from the STS acceptable.

The staff finds that the proposed TS 2.1.0, " Reactor Vessel Water Level" has been reformatted adopting the STS guidelines. The staff has reviewed the proposed TS against the STS and current TS requirements and finds that the proposed deviation between the proposed TS and the STS is acceptable.

In addition, the staff finds that the proposed TS does not relax any existing TS requirements. Therefore, the staff finds the proposed TSUP TS Section 2.1.D, t

" Reactor Vessel Water Level" acceptable, j

3.5 Power Transient Safety Limit Current TS 1.1.C contains a requirement for Power Transient Safety Limit. The proposed TS has eliminated this requirement. The STS guidelines have also

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eliminated this requirement. The current TS safety limit assumes the high neutron flux set point is exceeded for some period of time without a reactor scram. The Reactor Protection System (RPS) at Dresden and Quad Cities provides a highly reliable system which provides a reactor scram when neutron flux exceeds a given setpoint.

This safety limit is assumed to be exceeoed in the current analysis in the UFSAR.

In addition, in accordance with 10 CFR

=

t 50.62, additional equipment has been added to Dresden and Quad Cities to mitigate the effects of an anticipated transient without scram (ATWS) independent of the RPS. The Power Transient Safety Limit was in the original TS prior to the implementation of the modifications to meet 10 CFR 50.62. The safety limits recommended by STS guidelines and adopted in Sections 2.0, 3.2, and 3.11 of the proposed TSUP TS are sufficient to provide a conservative margin of safety against conditions which could represent a challenge to the fuel cladjing integrity and/or reactor coolant system integrity.

The 1

requirement for a Power Transient Safety Limit is outdated and other safety r

limits and safety systems provide equivalent protection. The staff has determined that the Power Transient Safety Limit is not required to be in the TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act. Further, it does not fall within any of the four criteria set forth in the Commission's Final Policy Statement discussed in Section 2.0 above. The staff, therefore, finds removal of the current TS Power Transient Safety Limit acceptable.

3.6 Section 2.2.A:

Reactor Protection System (RPS) Instrumentation Setooints Proposed TS Section 2.2.A, " Reactor Protection System (RPS) Instrumentation Setpoints," has been reformatted and incorporates the requirements of STS Section 2.2.1.

Proposed TS 2.2.A contains the trip setpoints for the reactor protection system instrumentation. The functional units specified in the proposed TS Section 2.2.A, Table 2.2.A-1 represent instrumentation which is used to protect the integrity of the reactor core and reactor coolant system.

The trip setpoints specified in proposed TS Section 2.2.A, Table 2.2.A-1 have been selected to ensure that the reactor core and reactor coolant system are prevented from exceeding their safety limits during normal operation and design basis anticipated operational occurrences and to assist in mitigating the consequences of accidents.

The proposed TS incorporates the existing safety limits from the current Dresden and Quad Cities TS, respectively.

The proposed TS has been reformatted into the Table format of the STS guidelines.

The current TS limiting safety system settings (LSSS) are currently divided into Section 2.1, " Fuel Cladding Integrity," and Section 2.2, " Reactor Coolant System." All of these safety limits have been incorporated into the proposed TS Table 2.2.A-1.

To be consistent with the format guidelines of the STS, safety limits functional units contained in current Dresden TS Table 3.1.1 and Quad Cities TS Table 3.1-1, 3.1-2, and 3.1-3 have been relocated to proposed

)

TS Table 2.2.A-1.

Proposed TS Section 2.2.A and associated Table 2.2.A-1 have been formatted in accordance with the STS guidelines. The following provides a discussion of the deviations between the proposed TS and the STS guidelines and an evaluation of differences and/or relocations of the current TS requirements.

Proposed TS 2.2.A and Table 2.2.A-1, Action statements, do not adopt STS nomenclature for " Allowable Values."

The proposed TS have replaced

" Allowable Values" with the current TS nomenclature, " Trip Level Settings."

The proposed TS " Trip Setpoint" is equivalent to STS "Allowabi Values." The STS also contain values for Trip Setpoint which are lower than the STS Allowable Values.

Operation with a trip set less conservative than its STS

1 Trip Setpoint but within its specified Allowable Value is acceptable on the basis that the difference between each Trip Setpoint and the Allowable Value is equal to or less than the drift allowance assumed for each trip in the safety analysis.

The STS requirements for " Trip Setpoint" have not been adopted in the proposed TS nor are they included in the current TS. This deviation from STS guidelines maintains consistency with current TS requirements and nomenclature. These values / parameters (STS " Trip Setpoint")

are more appropriately controlled administratively in other documents, i.e.,

UFSAR. The proposed TS has included the appropriate OPERABILITY limitation for the parameter (" Trip Setpoint") and this value is retained in the proposed TS.

Changes to the acceptance criteria detailed in these documents will be controlled by the provisions of 10 CFR 50.59.

In addition, including the STS allowable values may cause confusion with plant operators.

The staff, therefore, finds this deviation from the STS guidelines acceptable.

[JLNCTIONAL UNIT - IRM inoperative scram The "lRM Inoperative Scram 'N/A'" has been included in the proposed TS based on the plant design and to ensure consistency in function and format to current industry practice. This additional requirement deviates from STS guidance, but is merely an administrative enhancement to the STS requirements and has been added to maintain consistency in format to the TSUP requirements for APRMs which include an inoperative statement (STS Table 2.2.1-1, Item 1

2.d).

Because the proposed changes and devictions from STS do not reduce existing plant safety margins, the staff finds the proposed TS changes and deviations from STS guidelines acceptable.

l DLNCTIONAL UNIT - Averaae Power Ranae Monitor Proposed TS Table 2.2.A-1, Item 2.a for "Setdown Neutron Flux - High" is equivalent to the current TS Section 2.1.A.2.

STS terminology (" Neutron Flux

- Upscale, Setdown") has been reworded in the proposed TS to be consistent with existing plant terminology and the current design requirements. The Average Power Range Monitor (APRM) trip remains at 15 percent of rated thermal power.

The proposed TS for " Flow Biased Neutron Flux - High" deviates from STS guidelines to be consistent to the current TS.

TSUP Table 2.2. A-1, Item 2.b is changed as follows:

1.

STS terminology is modified to be consistent to the current TS.

The setpoints are maintained and the proposed TS deviates from STS terminology in order to maintain the current TS requirements.

STS terminology (" Flow Biased Simulated Thermal Power - Upscale") is equivalent to the proposed TS (" Flow Biased Neutron Flux - High")

and provides protection for the same requirement - the fuel cladding integrity safety limit.

STS terminology ("High Flow Clamped") is equivalent to the proposed TS for Dresden ("High Flow Maximum") and provides protection for the same requirement.

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2.

The >roposed TS section is separated into two categories depending on tie number of recirculation pumps running. The STS requirements for single recirculation loop operation (SLO) and dual recirculation loop operation (DLO) are not explicitly delineated. Splitting the requirements for SLO and DLO enhances STS requirements by providing greater clarity to plant operations personnel and maintains the requirements of the current:TS and the design requirements for each station. The staff, therefore, finds the above deviations from STS guidelines acceptable.

Quad Cities current TS have the "APRM Downscale" trip in TS Table 3.1-3,

" Reactor Protection System (Scram) Instrumentation Requirements Run Mode."

This requirement (APRM Downscale Trip) was not retained in the proposed TS.

The current action associated with this requirement is that "the APRM downscale trip function is automatically bypassed when the. Intermediate Range Monitor (IRM) instrumentation is operable and not high.". Removal of the APRM/IRM companion scram eliminates the APRM downscale scram which occurs in the Run mode with the simultaneous IRM scram that occurs with IRMs "high" or inoperable. This requirement provides no enhancement to safety and its elimination has been previously approved by the NRC staff (Dresden Units 2 and 3, Amendment Nos. 100/96 by letter dated August 24,1988) from the Dresden TS.

The proposed changes clarify the intent of the current Quad Cities specification by clearly defining the scram functions needed-to be_ operable in each mode of operation and does not involve any modification of the reactor protection system wiring or circuitry.

Proper overlap between the IRMs and APRMs is not affected. The staff has determined that the requirement for the APRM Downscale trip is not required to be in the TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act.

Further, it does not fall within any of the four criteria set forth in the Commission's Final Policy Statement discussed in Section 2.0 above.

Based on the above evaluation the staff finds that the deletion of the APRM downscale trip in the proposed TS is acceptable.

The requirements contained in the current Dresden and Quad Cities TS Section 2.1 for the operability and surveillance testing for both the APRM scram and the APRM Rod Block Trip Setting have been relocated to TSUP TS Section 3.2.E.

The acceptability of Section 3.2.E of the proposed TS will be evaluated along with the other proposed TS for Section 3/4.2. This change is acceptable.

FUNCTIONAL UNIT - Reactor Vessel Water level - Low The proposed TS Table 2.2.A-1, " Reactor Vessel Water Level - Low" deviates.

from STS terminology (STS specifies " Reactor Vessel Water Level - Low, level 3").

This deviation from STS guidance is based on current plant design and terminology at Dresden and Quad Cities Stations, is administrative in nature and does not compromise plant safety in any way. The proposed specification provides protection for the same requirements as STS - the fuel cladding integrity and reactor coolant system pressure safety limits. Therefore, the staff finds that maintaining the current TS terminology concerning the functional unit is an acceptable deviation from the STS guidelines.

a

4 '

The " Reactor Vessel Water Level - Low Low ECCS Initiation Trip Point,"

currently TS item 2.1.D, has been relocated to proposed TS 3.2.8.

The staff finds this change acceptable.

FUNCTIONAL UNIT - Main Steam Line Radiation - Hiah The " Main Steam Line Radiation" trip function is included in proposed TS Table 2.2.A-1 in accordance with STS guidelines. The trip setpoint of 15 times normal full power background remains unchanged from existing TS requirements for Quad Cities Station. The trip setpoint for Dresden of three times normal full power background is also unchanged from the current TS. The Dresden " Main Steam Line Radiation" trip setpoint for Unit 2 uses a dual setting dependent on the status of the Hydrogen Addition system. This deviates from the STS guidelines which do not account for hydrogen addition.

Both setpoints remain unchanged from the current Dresden TS.

Since the existing TS requirements are maintained and ensure existing plant safety margins are maintained, there is no reduction in plant safety proposed by these changes. The staff, therefore, finds the deviation from STS acceptable.

FUNCTIONAL UNIT - Scram Discharae Volume Water level - Hiah The " Scram Discharge Volume (SDV) Water Level - High" setpoints are included in proposed TS Table 2.2. A-1.

The specification is differentiated by the type of instrumentation for the high level trip. The differential pressure switches and the thermal switches or float switches are identified with the corresponding trip levels.

The proposed setpoints are given in gallons of water in the instrument volume.

In the current Dresden TS, the scram discharge volume trip setpoints are given in inches.

For Dresden, the trip setpoints are different for Unit 2 and Unit 3 due to design differences.

The current TS values in inches are equivalent to the proposed TS values expressed in gallons. The STS specifies the setpoint by " percent of full scale." The change in terms in the proposed TS does not adversely affect the current j

safety margins and provides protection for the same requirements - ensuring sufficient volume exists in the SDV system to accommodate a scram.

Since i

existing requirements are maintained and ensure existing plant safety margins are maintained, there is no reduction in plant safety proposed by these changes. The staff, therefore, finds the proposed changes acceptable.

FUNCTIONAL UNIT - Turbine EHC Control Oil Pressure Low Current TS Section 2.1.I, " Turbine Low Electro Hydraulic Control (EHC)

Pressure" scram function is included in proposed Section 2.2.A and Table 2.2.A-1.

The proposed specification is renamed " Turbine EHC Control Oil Pressure - Low." The STS requirements for this setpoint do not exist.

The setpoint of 900 psig remains unchanged from the current TS.

As such, the proposed TS provides equivalent protection to existing requirements.

Since existing TS requirements and existing plant safety margins are maintained, there is no reduction in plant scfety. The staff, therefore, finds this deviation from STS guidelines acceptable.

FUNCTIONAL UNIT - Turbine Condenser Vacuum low Current TS 2.1.J, " Condenser Low Vacuum Scram" (Quad Cities only) is included i

in proposed Table 2.2. A-1.

For Dresden Station, the " Condenser Low Vacuum i

Scram" is currently in Table 3.1.1, " Reactor Protection Instrumentation," and j

is relocated to proposed Table 2.2.A-1.

Although this requirement is not included within the STS, Comed has conservatively retained the " Condenser Low f

Vacuum Scram" function in the proposed TS.

In addition, the current setpoint for Dresden " Condenser Low Vacuum Scram" is 23 inches mercury (Hg) while Quad Cities' " Condenser Low Vacuum Scram" is 21 inches Hg. To maintain consistency between Dresden and Quad Cities where no design difference exists, Comed proposes to reduce Dresden's setpoint to 21 inches Hg. The loss of the main condenser vacuum results in the closure of the turbine stop valves and disables the turbine bypass function should the loss of vacuum continue to drop significantly. Closure of the stop valves without bypass, in turn, causes a pressure transient, neutron flux rise and increase in fuel cladding surface heat flux. However, closure of the turbine stop valves results in a reactor scram signal as soon as the valve position l

reaches 90 percent open. Thus, for a loss of condenser vacuum, the low l

condenser vacuum scram anticipates the subsequent stop valve closure and thereby results in a less severe reactor pressurization and fuel thermal heat flux rise. An instantaneous and total loss of vacuum represents the most severe loss of condenser vacuum which can be postulated.

Such an event would simultaneously cause fast closure of the turbine stop valves and prevent the bypass function while minimizing the beneficial effects of the anticipatory low condenser vacuum scram function. The consequences of this postulated event are bounded by the turbine trip without bypass transient, which assumes no credit for the anticipatory scram. Since the most severe licensing basis

{

turbine trip without bypass event does not take credit for the low condenser I

I vacuum scram, a change of the scram setpoint value will not affect the consequences for this limiting event. The staff, therefore, finds this reduction of the existing TS setpoint acceptable.

I f

Conclusion l

l The staff finds that the proposed TS for Section 2.2.A, "RPS Instrumentation Setpoints" has been reformatted adopting the STS guidelines. The staff has reviewed the proposed TS against the STS and current TS requirement and finds that all deviations from STS are acceptable and that the relaxation of the current TS maintains the design requirements for each station. Therefore, the staff finds the proposed TSUP TS Section 2.2.A, "RPS Instrumentation Setpoints" is acceptable.

3.7 Technical Specification Bases i

The staff has reviewed the proposed TS Bases for proposed TS 2.0, " Safety Limits and Limiting Safety System Settings." The Bases have been developed in i

accordance with the guidelines of the STS. Therefore, the staff finds the l

proposed TS Bases acceptable.

1 I

• 3.8 Doen Items All items in the current Dresden and Quad Cities TS Section 2.1 were not incorporated into Section 2.0 of the proposed TS. The remaining items from Section 2.1 will be relocated to other sections of the proposed TS. These should be left as open items, contingent upon their implementation in future TSUP amendments.

1.

Current TS 2.1.B. "APRM Rod Block Trip Setting" will be relocated to proposed TSUP TS 3.2.E.

2.

Current TS 2.2.B, " Primary System Safety Valve Nominal Settings" will be relocated to proposed TSUP TS 3.6.F.

3.

Current TS 2.1.D, " Reactor Water Level - Low Low ECCS Initiation Trip Point" will be relocated to proposed TSUP TS 3.2.B.

4.

Current TS 2.1.H, " Main Steamline Pressure Initiation of Main Steamline Isolation Valve Closure" will be relocated to proposed TSUP TS section 3.2.A.

3.9

SUMMARY

FOR SECTION 2.0 The proposed TSUP Section 2.0, " Safety Limits and Limiting Safety System Settings," clarifies the requirements of the current TS through the adoption of STS format, adds more restrictive requirements, and incorporates changes to correct inconsistencies with the STS.

In addition, all deviations between the STS guidelines and proposed TS and the relaxations of current TS have been determined by the staff to be consistent with the plant design requirements and adequate justification has been provided to support these deviations and relaxations.

Therefore, the staff finds the proposed amendment for TSUP TS Section 2.0 acceptable.

4.0 EVALUATION OF PROPOSED TS SECTION 3/4.11 " POWER DISTRIBUTION LIMITS" The following sections provide the staff's evaluation of the TS changes reflected in proposed TSUP TS Section 3/4.11. The proposed TS 3/4.11 is a new specification that results from the consolidation and rearrangement of the existing TS requirements for power distribution limits. The majority of the proposed specifications are currently contained in TS Section 3/4.5, "ECCS Systems." The new specifications have been developed using the STS guidelines. The proposed TS are evaluated below.

4.1 TS 3/4.ll.A: AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

Proposed TS 3/4.11.A, " AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR),"

incorporates the requirements of STS 3/4.2.1 and requirements from current TS Section 3/4.5.I.

Plant specific values for the listed parameters are included which are consistent with the UFSAR for the plants. Both Dresden and Quad Cities had placed the cycle specific parameters in a Core Operating Limits

Report (COLR) through a previous amendment request. The COLR is controlled in Section 6.0 of the current and proposed TSUP TS. The proposed changes are consistent with the STS guidelines and Generic Letter 88-16, " Removal of Cycle Specific Parameters From Technical Specifications."

4.1.1 Aeolicability The applicability of the current and proposed TS is equivalent based upon comparison of the SR of current TS Section 4.5.I and the applicability statements of proposed TS Section 3.11.A.

The applicability of the proposed TS enforces APLHGR determination when the reactor is in OPERATIONAL MODE I and greater than or equal to 25 percent rated thermal power.

Similarly, the SR in the current TS only require the APLHGR values to be determined when the reactor is at greater than or equal to 25 percent rated thermal power.

4.1.2 LCQ The proposed LC0 for 3.11.A deviates in terminology from STS for Dresden Station only. The proposed Dresden TS uses the terminology " bundle average exposure" as opposed to STS terminology " AVERAGE PLANAR EXPOSURE." The STS terminc!ogy is not applicable to the fuel design used at Dresden Station.

The proposed deviation is administrative in nature, is consistent to STS requirements, and does not affect the safe operation of Dresden Station. The staff, theefore, finds the deviation acceptable.

4.1.3 Actions The proposed actions for TS Section 3/4.11.A are adopted from STS, but are separated for clarification purposes. The proposed wording is consistent with STS guidelines.

An alteration of the current TS action statement was identified in the proposed TS. Current TS Section 3.5.1 requires corrective action to be taken within 15 minutes if it is determined by normal surveillance that the limiting value for APLGHR is being exceeded. This is consistent with proposed TS Section 3.11.A Action 1.

The current TS then allows a 2-hour period in which to return APLHGR within prescribed limits, and, if this is not achieved, the reactor shall be brought to cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The proposed TS alters the action requirement by stating that if the limits are not restored within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the reactor is to be brought to less than 25 percent rated thermal power within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The action of the proposed TS is consistent with STS guidance.

The APLHGR limits are primarily derived from fuel design evaluations and loss-of-coolant accident (LOCA) and transient analyses that are assumed to occur at high power levels. Design calculations and operating experience have shown that as power is reduced, the margin to the required APLHGR limits increases.

This trend continues down to the power range of 5 percent to 15 percent rated thermal power when entry into Mode 2 occurs. When in Mode 2, the intermediate range monitor scram function provides prompt scram initiation during any

f

• significant transient, thereby effectively removing any APLHGR limit compliance concern. Therefore, at thermal power levels less than 25 percent rated thermal power, the reactor is operating with substantial margin to the APLHGR limits and the level of safety provided by the APLHGR limit is minimal.

In addition, the current TS SR only requires APLHGR determination above 25 percent rated thermal power. Therefore, the applicability of the thermal limits is only above 25 percent rated thermal power.

Reducing power beyond the proposed TS action requirement (i.e., to cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />) results in unnecessary thermal cycles of the reactor vessel and unnecessary challenges to safety systems. Therefore, the staff finds that the deletion of the requirement to bring the reactor to cold shutdown is acceptable.

Based on the above evaluation, the staff finds that the proposed TS for Section 3/4.ll.A, APLHGR, has been reformatted adopting the STS guidelines.

The staff has reviewed the proposed TS against the STS and current TS requirements and finds that all deviations from the STS are acceptable and the proposed TS do not relax any existing TS requirements. Therefore, the staff finds the proposed TS 3/4.ll.A acceptable.

4.2 TS 3/4.11.B. "APRM SETPOINTS" Proposed TS 3/4.11.B, "APRM SETPOINTS," incorporates the requirements of STS 3/4.2.2.

Plant specific values for the listed parameters are included to be consistent with the UFSAR for the plants. The proposed TS incorporates the existing TS requirements concerning APRM setpoints from current TS Sections 2.1.A.1, 2.1.A.2, and 2.1.B.

The proposed changes are consistent with the STS and Generic Letter 88-16, " Removal of Cycle Specific Parameters from Technical Specifications." Both Dresden and Quad Cities had placed the cycle specific parameters in a COLR through a previous amendnent request.

The COLR is controlled in Section 6.0 of the current and proposed TS.

There are no significant changes and/or deviations from STS guidance or relaxation of current TS requirements.

The proposed TS change is administrative in nature and, therefore, does not reduce the margin of safety for Dresden or Quad Cities Stations.

4.2.1 LfD Proposed TS LC0 3.11.B adopts the STS format, but deviates due to plant specific / fuel vendor specific terminology / methodology.

Enhancements to STS guidelines are made to avoid duplicating setpoints within the proposed TS and to more clearly delineate when the actions for the specification are to be implemented. The proposed LC0 requirements are consistent with the current TS requirements in place at Dresden and Quad Cities Stations, and includes the intent of the STS guidelines.

i Proposed TS 3.11.B is provided to require the APRM gain or APRM flow biased scram and rod block trip,setpoints to be adjusted when operating under conditions of abnormal power peaking so that acceptable margin to the fuel cladding integrity limits are maintained. For Quad Cities, abnormal power peaking is represented by the Maximum Fraction of Limiting Power Density

~ (MFLPD) being greater than the Fraction of Rated Thermal Power (FRTP).

For Dresden, abnormal power peaking is represented by the Fuel Design Limiting Ratio For Centerline Melt (FDLRC) being greater than 1.0.

These thermal limits are different for Dresden and Quad Cities due to the different fuel vendor suppliers for the plants (General Electric Company (GE) currently supplies fuel to Quad Cities and Siemens Nuclear Power (SNP) currently supplies fuel to Dresden). The different fuel vendors utilize different requirements and terminology to describe the thermal limitations placed upon their respective fuel designs. However, the basis of these thermal limits remains equivalent - to maintain the integrity of the fuel cladding.

To maintain the appropriate margin under conditions of abnormal power peaking, either the APRM gain must be adjusted upward or the flow biased neutron flux upscale scram trip and rod block setpoints be reduced.

This is accomplished by multiplying the APRM gain or setpoints by a factor that is representative of the reduction in margin to the fuel cladding integrity limits. Adjustment to the scram and rod block setpoints are made by multiplying the setpoint by the inverse of the factor for the APRM gains. This factor will be less than one and, therefore, will cause the setpoints to be lowered to maintain the margin. When the reactor is operating with normal peaking (i.e., FDLRC < 1.0 or MFLPD < FRTP) it is not necessary to modify the APRM flow biased scram or rod block setpoints. These requirements are consistent with current TS requirements and do not reduce existing plants safety margins.

4.2.2 Actions The proposed Actions in TSUP 3.11.B are adopted from STS, but are separated for clarification purposes. The current TS do not contain an action statement associated with this TS. The licensee has adopted required actions in accordance with the STS guidelines.

The proposed action requires that if FDLRC is greater than 1.0 for Dresden or MFLPD is greater than FRTP for Quad Cities, that within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> the limit is restored, or the APRM setpoints in the proposed TS Section 2.2.A and 3.2.E are adjusted, or the APRM gains are adjusted. These thermal limits are different for Dresden and Quad Cities due to the different fuel vendor suppliers. The different fuel vendors utilize different requirements and terminology to describe the thermal limitations placed upon their respective fuel designs.

However, the basis of these thermal limits remains equivalent to maintain the integrity of the fuel cladding.

If the action provisions are not met, thermal power is required to be reduced to below 25 percent of rated thermal power. The proposed required i

actions in the TS are consistent with STS guidelines.

Based on the above i

evaluation, the staff finds the proposed actions acceptable.

4.2.3 Surveillance Reauirements The proposed TS SRs are adopted from the STS guidelines.

Proposed TS 4.11.B requires that the value of FDLRC (Dresden) or MFLPD and FRTP (Quad Cities) be i

checked at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; initially within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after a thermal power increase of 15 percent or more, and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the reactor is operating on a limiting control rod pattern.

Proposed TSUP TS 4.ll.B.4 is

C

_ 17 _

added to stipulate that the provisions of proposed TS 4.0.D are not applicable per the requirement of GL 87-09.

The proposed changes are consistent and/or more conservative than existing TS requirements; therefore, the proposed TS does not reduce the margin of safety for the plants. The staff, therefore, finds the proposed TS SR acceptable.

4.2.4 Conclusion Based on the above evaluation, the staff finds the proposed TS 3/4.11.8, "APRM SETPOINTS" has adopted the guidelines of STS and has not relaxed any current TS requirements. Therefore, the staff finds the proposed TS acceptable.

4.3 TS 3/4.11.C: MINIMUM CRITICAL POWER RATIO Proposed TS 3/4.11.C, " MINIMUM CRITICAL POWER RATIO," incorporates the requirements of STS 3/4.2.3 and current TS Section 3/4.5.L for Dresden and 3.5/4.5.K for Quad Cities.

Plant specific values for the listed parameters are included which are consistent with the UFSAR for both Dresden and Quad Cities.

The proposed changes are consistent with the STS and GL 88-16.

Both Dresden and Quad Cities have cycle specific parameters placed in a COLR. The proposed amendment request is administrative in nature and, therefore, does not reduce the margin of safety for Dresden or Quad Cities Stations.

4.3.1 Action The proposed action statement implements the requirements of the current TS with the exception that the proposed TS do not require the reactor to be taken to cold shutdown if the MCPR limit is not restored within the 2-hour time frame. The proposed TS alters the action requirement by stating that if the limits are not restored within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the reactor is to be brought to less than 25 percent rated thermal power within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The action of the proposed TS is consistent with STS guidance.

The MCPR limits are primarily derived from fuel design evaluations and LOCA and transient analyses that are assumed to occur at high power levels. Design calculations and operating experience have shown that as power is reduced, the margin to the required MCPR limits increases. This trend continues down to the power range of 5 percent to 15 percent rated thermal power when entry into Mode 2 occurs. When in Mode 2, the intermediate range monitor scram fLnction provides prompt scram initiation during any significant transient, thereby effectively removing any MCPR limit compliance concern. Therefore, at thermal power levels less than 25 percent rated thermal power, the reactor is operating with substantial margin to the MCPR limits and the level of safety provided by the MCPR limit is minimal.

In addition, the current TS SR only requires MCPR determination above 25 percent rated thermal power.

Therefore, the applicability of the thermal limits is only above 25 percent rated thermal power. Reducing power beyond the proposed TS action requirement (i.e., to cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />) results in unnecessary thermal cycles of the reactor vessel, and unnecessary challenges to safety systems. Therefore, the

' deletion of the requirement to bring the reactor to cold shutdown is acceptable.

4.3.2 Surveillance Reauirements In proposed TS 4.11.C.1, the licensee proposed differing values for t for y

Dresden and Quad Cities The basis for the differing values is differing fuel vendors. The proposed falues are consistent with current TS requirements and do not reduce the margin of safety for either Dresden or Qur.J Cities. The staff, therefore, finds this change acceptable.

4.3.3 Conclusion Based on the above evaluation, the staff finds that proposed TS 3/4.11.C,

" MINIMUM CRITICAL POWER RATIO" has adopted the guidelines of STS and the deviation from the current TS requirements does not reduce the margin of safety. Therefore, the staff finds the proposed TS acceptable.

4.4.

TS 3/4.11.D:

STEADY STATE LINEAR HEAT GENERATION RATE (Dresden)

TS 3/4.ll.D:

LINEAR HEAT GENERATION RATE (Quad Cities)

Proposed TS 3/4.11.0, " STEADY STATE LINEAR HEAT GENERATION RATE" (Dresden) and

" LINEAR HEAT GENERATION RATE" (Quad Cities), incorporate the requirements of STS 3/4.2.4 and current TS 3/4.5.J for both stations.

The difference in title for these proposed TS is due to the difference in fuel vendors at each site (Quad Cities - GE, Dresden - SNP).

Plant specific values for the listed parameters are included which are consistent with the UFSAR for the plants.

The proposed changes are consistent with the STS and Generic Letter 88-16.

Both Dresden and Quad Cities have the cycle specific parameters placed in a COLR. The proposed TS change is administrative in nature and, therefore, does not reduce the margin of safety for Dresden or Quad Cities Stations.

The proposed action statement implements the requirements of the current TS with the exception that the proposed TS do not require the reactor to be taken to cold shutdown if the LHGR limit is not restored within the 2-hour time frame. The proposed TS alters the action requirement by stating that if the limits are not restored within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the reactor is to be brought to less than 25 percent rated thermal power within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The action of the proposed TS is consistent with STS guidance.

The LHGR limits are primarily derived from fuel design evaluations and LOCA and transient analyses that are assumed to occur at high power levels. Design l

calculations and operating experience have shown that as power is reduced, the margin to the required LHGR limits increases.

This trend continues down to the power range of 5 percent to 15 percent rated thermal power when entry into i

Mode 2 occurs. When in Mode 2, the intermediate range monitor scram function provides prompt scram initiation during any significant transient, thereby effectively removing any LHGR limit compliance concern. Therefore, at thermal power levels less than 25 percent rated thermal power, the reactor is operating with substantial margin to the LHGR limits and the level of safety l

f provided by the LHGR limit is minimal.

In addition, the current TS SR only requires LHGR determination above 25 percent rated thermal power. Therefore, the applicability of the thermal limits is only above_25 percent rated thermal power.

Reducing power beyond the proposed TS action requirement (i.e., to cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />) results in unnecessary thermal cycles of the reactor vessel, and unnecessary challenges to safety systems.

Based on its evaluation, the staff finds that the proposed TS 3/4.11.D,

" STEADY STATE LINEAR HEAT GENERATION RATE" (Dresden) and 3/4.11.D, " LINEAR HEAT GENERATION RATE" (Quad Cities) have been reformatted adopting the STS guidelines. The staff has reviewed the proposed TS against the STS and current TS requirement and finds that there are no significant deviations from STS and the deviation from current TS requirements does not reduce the margin of safety. Therefore, the staff finds the proposed TS 3/4.11.D, " STEADY STATE LINEAR HEAT GENERATION RATE" (Dresden) and 3/4.11.D " LINEAR HEAT GENEPATION RATE" (Quad Cities) are acceptable.

4.5 TS 3/4.11.E: TRANSIENT LINEAR HEAT GENERATION RATE (Dresden Only)

Y Proposed TS 3/4.ll.E, " TRANSIENT LINEAR HEAT GENERATION RATE" (Dresden only),

incorporates the requirements of STS 3/4.2.4 and current TS 3/4.5.K.

Plant specific values for the listed parameters are included which are consistent with the UFSAR for the plant. This additional power distribution limit for t

Dresden is due to fuel vendor specific design differences. The proposed changes are consistent with the STS and Generic Letter 88-16. There are no significant changes and/or deviations from STS guidance.

TS 3/4.11.E is unchanged from the current TS with the exception of an additional SR (TS 4.ll.D.1) which is based on STS.

There is no relaxation of current TS requirements. The proposed TS change is administrative in nature and, therefore, does not reduce the margin of safety for Dresden.

Based on the above evaluation, the staff finds that the proposed TS for Section 3/4.11.E, " TRANSIENT LINEAR HEAT GENERATION RATE" (Dresden only) has been reformatted adopting the STS guidelines.

The staff has reviewed the proposed TS against the STS and current TS requirement and finds that there are no significant deviations from STS and the proposed TS do not relax any existing TS requirements. Therefore, the staff finds the proposed TS 3/4.ll.E, " TRANSIENT LINEAR llEAT GENERATION RATE" (Dresden only) acceptable.

4.6 Technical Specification Bases The staff has reviewed the proposed TS Bases for proposed TS 3/4.11, " POWER DISTRIBUTION LIMITS." The Bases have been developed in accordance with the guidelines of the STS. Therefore, the staff finds the proposed TS Bases acceptable.

4.7 CONCLUSION

- PROPOSED TSUP SECTION 3/4.11 POWER DISTRIBUTION LIMITS The proposed TS changes for TS 3/4.11, " Power Distribution Limits," are administrative in nature and do not adversely affect the safe operation of

• l 1

l l

Dresden or Quad Cities Stations. The propcsed TS clarifies the requirements i

of the present TS through the adoption of STS format, adds more restrictive I

requirements, and incorporates changes to correct inconsistencies with the

(

1 STS. As indicated above, the staff has evaluated all deviations between the l

proposed TS and the STS and found them acceptable.

In addition, the staff l

compared the proposed TS with the current TS requirements and found no relaxation of current requirements. Therefore, the staff finds the proposed TS 3/4.11 is acceptable.

5.0 EVALUATION OF PROPOSED TS 3/4.12. "SPECIAL TEST EXC_EPTIONS" 5.1 TS 3/4.12.A:

PRIMARY CONTAINMENT INTEGRITY l

Proposed TS 3/4.12.A " PRIMARY CONTAINHENT INTEGRITY," incorporates the requirements of STS 3/4.10.1 and requirements from Section 3.7.A.2 of the current TS for both stations.

Plant specific values for the listed parameters are included which are consistent with the UFSAR for the plants.

The proposed TS change request does not reduce the margin of safety for Dresden or Quad l

Cities Stations.

The staff identified one deviation from STS in the proposed TS.

The proposed specification allows the primary containment integrity requirements to be l

I suspended for the purpose of performing low power physics tests with thermal power less than 1 percent of rated thermal power and the reactor coolant temperature less than 212 *F.

The STS specifies a temperature requirement of 200 *F.

A temperature of 212 *F is consistent with the current TS and is 1

retained in the proposed TS for consistency with the proposed operational 1

modes defined in proposed TSUP TS Section 1.0.

The difference between 212 *F and 200 *F results in an insignificant change in water density so the coolant provides the same moderator effect and essentially an equivalent level of safety protection. The evaporation rate may be higher at 212 *F, but the airborne limits are controlled by 10 CFR 20 limits and are encompassed with the safety analysis. The staff, therefore, finds this deviation from STS guidelines acceptable.

A relaxation of current TS was also identified.

Current TS Section 3.7.A.2 requires the reactor power to be less than five MWt to perform low power physics tests.

Five MWt equals approximately 0.2 percent rated thermal power.

The proposed TS uses 1 percent rated thermal power for consistency to STS.

The intent of the current TS is to complete the low power physics testing at the low end of the APRM scale. To meet this intent, I percent rated thermal power and 0.2 percent rated thermal power fulfill the same purpose.

Five MWt is very difficult to detect on the APRM scale and, therefore, was never measured accurately.

Performing these tests at 1 percent versus 0.2 percent power will have no effect on the safety limits. The staff has deten.iined that the change from the current TS does not reduce existing plant safety margins, and, therefore, the change is acceptable.

Based on its evaluation, the staff finds that the proposed TS 3/4.12.A,

" PRIMARY CONTAINMENT INTEGRITY" has been reformatted adopting the STS

e e guidelines.

The staff has reviewed the proposed TS against the STS and current TS and finds that the deviation from STS is acceptable and the relaxation of existing TS requirements is acceptable. Therefore, the staff finds the proposed TSUP TS Section 3/4.12.A, " PRIMARY CONTAINMENT INTEGRITY" acceptable.

5.2 Section 3/4.12.B:

SHUTDOWN MARGIN DEMONSTRATIONS Proposed TS 3/4.12.B, " SHUTDOWN MARGIN DEMONSTRATIONS," incorporates the requirements of STS 3/4.10.3 and current TS 3.3.B.3.b.

Plant specific values for the listed parameters are included which are consistent with the UFSAR.

There is no relaxation of current TS requirements. The proposed amendment request is administrative in nature and, therefore, does not reduce the margin of safety for Dresden or Quad Cities Stations. The staff identified the following deviations from STS:

Proposed TS 4.12.B.1 deviates from STS guidelines by stipulating that the s,horting links also be removed to demonstrate operability. The proposed SR is consistent with current requirements and removes an inconsistency between LC0 3.12.B.1 and the SR. The staff, therefore, finds this deviation from STS 1

guidelines acceptable.

Proposed TS 4.12.B.2 deviates from STS guidelines by allowing "other technically qualified individual" to be used instead of STS terminology which specifies "other technically qualified member of the unit technical staff."

This proposed terminology clarifies ambiguities in the STS that are unnecessary and does not constitute a reduction in current requirements.

The proposed change is administrative in nature and, therefore, does not reduce the safety margin of the plant.

The staff, therefore, finds this deviation from the STS guidelines acceptable.

Based on its evaluation, the staff finds that the proposed TS 3/4.12.B,

" SHUTDOWN MARGIN DEMONSTRATIONS" has been reformatted adopting the STS guidelines. The staff has reviewed the proposed TS against the STS and current TS requirement and finds that all deviations from STS are acceptable and the proposed TS do not relax any existing TS requirements. Therefore, the staff finds the proposed TS 3/4.12.B.

" SHUTDOWN MARGIN DEMONSTRATIONS" acceptable.

5.3 Technical Specification Bases The staff has reviewed the proposed Bases for TS 3/4.12. The proposed Bases have been prepared using the guidelines of the STS. The staff finds these proposed Bases acceptable.

5.4 CONCLUSION

The changes in proposed TS 3/4.12, "Special Test Exceptions," are administrative in nature and do not adversely affect the safe operation of Dresden and Quad Cities Stations.

The proposed TS clarifies the requirements

i e

[

' i of the present TS through the adoption of STS format, adds more restrictive requirements, and incorporates changes to correct inconsistencies with the STS. Based on the above evaluation, the staff finds the proposed TS 3/4.12 acceptable.

6.0 StMtARY The proposed TS for Sections 2.0, 3/4.11 and 3/4.12 will be clearer and easier to use as a result of the adaptation of the STS format. The changes result in additional limitations, restrictions, or changes based on generic guidance.

It is the staff's assessment that the changes proposed in this amendment'do not pose any decrease in safety, or an increase in the probability of an analyzed or unanalyzed accident. The revised TS changes do not reduce the existing margin of safety set forth by the current TS. Therefore,.the staff finds the proposed TS changes acceptable.

l

7.0 STATE CONSULTATION

l In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendments. The State' official had no comments.

8.0 LNVIRONMENTAL CONSIDERATION The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (60 FR 24906). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

9.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors:

J. Stang/D. Skay Date: June 13,1995 I

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