ML20085L696
| ML20085L696 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities  |
| Issue date: | 06/14/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20085L689 | List: |
| References | |
| NUDOCS 9506280611 | |
| Download: ML20085L696 (10) | |
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' UNITED STATES
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j NUCLEAR REGULATORY COMMISSION l
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WASHINGTON, D.C. 2000H001 o
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.135 TO FACILITY OPERATING LICENSE NO. DPR-19.
l AMENDHENT NO. 129TO FACILITY OPERATING LICENSE NO. DPR-25.
AMENDMENT NO.156 TO FACILITY OPERATING LICENSE NO. DPR-29.
- AND AMENDMENT NO.152 TO FACILITY OPERATING LICENSE NO. DPR-30 COMMONWEALTH EDISON COMPANY
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&lE IOWA-ILLIN0IS GAS AND ELECTRIC COMPANY DRESDEN NUCLEAR POWER STATION. UNITS 2 AND 3 OVAD CITIES NUCLEAR POWER STATION. UNITS 1 AND 2 f
DOCKET NOS. 50-237. 50-249. 50-254 AND 50-265
1.0 INTRODUCTION
By letter dated December 15, 1993, as supplemented by letter dated April 21,.
1995, Commonwealth Edison Company (Comed, the licensee) submitted an amendment i
1 requesting to upgrade a section 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 i
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 focused on the existing custom Technical Specifications used at the sites.
Commonwealth Edison made the decision to initiate a Technical Specification Upgrade Program (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 i
Specifications General Electric Plants BWR/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 eliminate the need for interpretation, and deleting requirements that are no longer considered 9506200611 950614 DR ADOCK 050002 7
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, 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.
The TSUP for Dresden and Quad Cities is not a complete adoption of the STS.
The TSUP focuses on (1) the integration of additional information such as equipment operability requirements during shutdown conditions, (2) clarification of requirements such as limiting conditions for operations and action statements utilizing STS terminology, (3) deletion of superseded requirements and modifications to the TS based on the licensee's responses to Generic Letters (GL), and (4) relocation of specific items to more appropriate TS locations.
The application dated Ib ember 15, 1993 as supplemented April 21, 1995, proposed to upgrade (niy those sections of the TS to be included in TSUP section 5.0 (Design Fee"_ies) of the Dresden and Quad Cities TS.
i 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 licensees' 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 huREG-0123 were developed by the NRC and industry because of the shortcomings assoc!ated with the custom TS which were issued to plants licensed in early 1970's (i.e., Dresden (1971) and Quad Cities (1972)).
The i
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 ope ating 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.
. For 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 station'a UFSAR respectively.
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 the deviations 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 Chanaes - Non-technical, administrative changes were intended to incorporate human factor principles into the form and structure of the STS so that they would be easier to use for plant operation's personnel.
These 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 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, resent TS to be operable; adding more restrictive requirements to restore inoperable equipment; and adding more restrictive surveillance requirements.
Less Restrictive Reauirements - The licensee provided a justification for less restrictive requirements on a case-by-case basis as discussed in this SE.
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 design was reviewed to determine if the specific design basis was consistent with the STS contained in NUREG-0123.
All changes to the current TS and deviations between the licensees' proposed TS and the STS were reviewed by the staff for acceptability to determine if
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adequate justification was provided (i.e., plant specific features, retention of existing operating values, etc.).
Deviations the stsff finds acceptable include:
(1) the addition of clarifying.
4 statements,-(2) incorporating changes based on GL, (3) reformatting multiple steps included under STS action statements into single steps with unique 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 Specifications - The proposed TS include the relocation of some requirements from the TS to licensee-controlled documents.
Section 182a of the Atomic Energy Act requires applicants for nuclear power I
plant operating licenses to state Technical Specifications to be included as..
part of the. license. The Commission's regulatory requirements related to the 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, limiting safety system settings, and limiting control settings; (2) limiting 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 i
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 matter is required to be included in the TS, as follows:
(1) Installed instrumentation j
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 j
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 success path and which functions or actuates to mitigate a Design Basis Accident of Transient that either assumes the failure of,or presents a
- challenge to the integrity of a fission product barrier; (4) a structure, system, or component.which operating experience or probabilistic safety I
assessment has shown to be significant to public health and safety. As a j
result, existing TS requirements which fall within or satisfy any of the l
criteria in the Final Policy Statement must be retained in the TS, while those 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
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proposed TS changes.
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. 3.0 EVALUATION OF TSUP PROPOSED TS SECTION 5.0. DESIGN FEATURES Proposed Section 5.0 contains the design features for the Dresden and Quad Cities Stations and provides the necessary controls of those features. The proposed TS incorporate the requirements of the current TS Section 5.0 for both Dresden and Quad Cities.
Each change from the current TS requirements and deviations from the STS requirements are described below.
3.1 Section 5.1. Site Proposed TSUP Section 5.1, " Site," incorporates the guidelines of STS Section 5.1 and all existing TS requirements from Section 5.1 for both Dresden and Quad Cities. Plant-specific Figures 5.1.B-1, Low Population Zone are consistent with the safety analysis for the plant.
The proposed Figures 5.1.B-1 provided in the December 15, 1993, submittal were unclear.
This item is left as an open item contingent upon correction in the TSUP cleanup amendment.
In addition, the licensee did not include the STS figure concerning the exclusion area. This item is also left as an open item.
Based on discussions between the NRC staff and Comed, Figure 5.1.A-1 for the Exclusion Area will be added in the cleanup amendment.
The location and/or description of the Meteorological Tower will be added to Figure 5.1. A-1.
The references regarding the OFFSITE DOSE CALCULATION MANUAL (0DCM) in proposed TS Sections 5.1.C and 5.1.D are consistent with the current.TS requirements and with the guidance of GL 89-10.
3.2 Section 5.2. Containment Proposed TSUP Section 5.2, " Containment," incorporates the guidelines of STS Section 5.2 and existing TS requirements from Section 5.4 for both Dresden and Quad Cities.
Plant specific values for the listed parameters are included to be consistent with the UFSAR for the plants. Deviations from STS requirements are discussed below. The TSUP Section 5.2 is proposed to incorporate the containment design provisions determined necessary by STS guidelines to assure that the containment response analyses assumptions remain valid.
Current TS Section 5.4 provides only a general reference to the UFSAR regarding general design parameters.
Proposed Section 5.2 identifies only the critical design features and provides a description rather than referencing the UFSAR.
Revisions to other parameters not included in the proposed TS will continue to be adequately controlled in the UFSAR by the requirements of 10 CFR 50.59.
This change from current TS is acceptable.
The licensee deviated from STS guidance by providing a range of values rather than a nominal value in the description of the centainment configuration.
The proposed values are consistent with other TS requirements for water level (upper and lower limits).
Because the change does not invalidate other TS requirements and is consistent with current design basis requirements described in the UFSAR, the NRC staff finds the proposed deviation from the STS guidelines acceptable.
l 3.3 Section 5.3. Reactor Core Proposed TSUP Section 5.3, " Reactor Core," incorporates the guidelines of STS Section 5.3 and the current TS requirements of Section 5.2 for Dresden and Quad Cities.
Plant-specific values for the listed parameters are included to be consistent with the UFSAR for the plants.
The proposed TS incorporates the reactor core and control rod design provisions determined necessary by STS guidelines to assure that the reactor physical content and arrangement does not change. The proposed TS Section 5.3.A deviates from STS and from the current TS Section 5.2, per the guidance provided in GL 90-02, Supplement 1, in that it allows limited substitutions of fuel assemblies in accordance with NRC approved applications.
The purpose of this section is to define / describe fuel assemblies at Dresden and Quad Cities. Significant changes in bundle designs are controlled pursuant to 10 CFR 50.59.
Because the proposed wording is consistent with the fuel bundle design features at Dresden and Quad Cities and the guidelines of GL 90-02, Supplement 1, the staff finds the proposed deviation from STS guidelines and from current TS 5.2 acceptable.
Proposed TS Section 5.3.B deviates from the current TS in the design requirements for the control rods. The proposed TS deletes the statement that the boron carbide powder is compacted to approximately 70 percent theoretical density. The design of the control rods is included in the UFSAR Section 4.6.2.1.
Any changes to the design are controlled pursuant to 10 CFR 50.59 and therefore, it is not necessary to control this design feature in the TS.
The staff has determined that the requirements for the density of the boron carbide powder are not required to be in the TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act.
Further, they do not fall within any of the four criteria discussed in Section 2.0 above.
In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.59 to assure continued protection of public health and safety. The proposed TS also adds the requirement that the control rod assembly shall have a nominal axial absorber length of 143 inches. This is an enhancement of the current TS, based on STS guidance and is acceptable.
3.4 Section 5.4. Reactor Coolant System Proposed TS Section 5.4, " Reactor Coolant System," incorporates the requirements of STS Section 5.4 and the requirements of current TS 5.3 for Dresden and Quad Cities.
Plant-specific values for the listed parameters are included to be consistent with the UFSAR for the plants.
Section 5.4 is proposed to incorporate the reactor coolant system specific design provisions of pressure, temperature and volume. Deviations exist between the proposed TS and STS guidance. The proposed TS use specific reference of individual pressures and temperatures for each parameter, while STS guidance only stipulates a single temperature for all parameters. This deviation from STS guidance is based on the current design basis at Dresden and Quad Cities and ensures that the safety analyses assumptions remain valid.
The staff finds the proposed deviation from the STS guidelines acceptable.
i I t Current TS Section 5.3 provides only a general reference to the UFSAR f
concerning design parameters for the reactor vessel only, not the complete reactor. coolant system. The proposed TS identifies only specific features of t
the entire reactor coolant system and provides a' description per the STS guidelines rather than referring to the UFSAR. Revisions to parameters not i
included in the proposed TS will be adequately controlled in the UFSAR by the requirements of 10 CFR 50.59. The staff finds this acceptable.
j Proposed TSUP Section 5.4 provided in the December 15, 1993, submittal contained an incorrect reference to the FSAR on TS pages 5-4 and 5-8 for both stations.
Per discussions with the licensee, the appropriate TS pages were i
revised to reference the UFSAR instead of the FSAR. This is an editorial change and is acceptable.
The proposed changes are consistent with the current design basis as described in the UFSAR. Therefore, the staff finds the proposed deviation from the STS i
guidelines and current TS acceptable.
3.5 Section 5.5. Meteoroloaical Tower Location l
The proposed TS does not incorporate the requirements of STS Section 5.5,
" Meteorological Tower Location," which references a separate figure showing I
the location of the meteorological tower.
In lieu of providing a separate figure for the meteorological tower, the proposed TS will show the location of-I the meteorological tower in Figure 5.1.A-1, " Exclusion Area". More detailed information on the meteorological tower is included in the 00CM in accordance with the guidance of GL 89-01. Because the proposed change is consistent with the guidelines of GL 89-01, and the meteorological tower location will be shown in the proposed TS, the staff finds the proposed deviation from STS guidelines acceptable.
1 3.6 Section 5.6. F_yel Storaae
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Proposed TS Section 5.6, " Fuel Storage," incorporates the guidelines of STS Section 5.6 and current TS requirements of Section 5.5 for both Dresden and Quad Cities.
Plant-specific values for the listed parameters are included to be consistent with the UFSAR for the plants.
Proposed Section 5.6 incorporates the fuel storage design provisions determined necessary by STS to assure that the spent fuel is appropriately stored and cooled.
The proposed Section 5.6 deviates from both the current TS and STS in the requirements for new fuel storage. The current TS specify a reactivity limit for new fuel storage which has been eliminated in the proposed TS. The UFSAR Section 9.1.1 states the maximum number of new fuel bundles that can be stored and the minimum center-to-center spacing that will prevent an accidental critical array. Therefore, the design in the new fuel storage system ensures that the limits in the current TS will not be exceeded. Changes to the UFSAR are controlled by the requirements of 10 CFR 50.59.
These requirements are more appropriately controlled in the UFSAR. The staff has determined that the requirements for new fuel storage are not required to be in the TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act.
Further, they do not fall
. within any of the four criteria discussed in Section 2.0 above.
In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.59 to assure continued protection of public health and safety. Therefore, this change from the current TS is acceptable. The STS requires design limits for storage of new fuel only for the initial core loading. This STS requirement is no longer applicable for Dresden and Quad Cities and therefore, this deviation from STS is acceptable.
The proposed TS deletes some of the current TS requirements with regard to the maintenance of K,,, and K for the Dresden station. The proposed TS only require that a K equivUent to less than or equal to 0.95 be maintained in the spent fuel sl,o, rage racks. The requirements for K in the current TS are more appropriately controlled in the UFSAR. K Dmitsarefueltype dependent, which could be cycle dependent and sNo/KuNbecontainedwithinthe UFSAR. The design of the fuel racks ensures that a maximum K is not exceeded and, therefore, the fuel cycle need not be analyzed Io,r such limits.
The proposed TS add a requirement that a nom'nal center-to-center distance be maintained between the fuel assemelies in the storage racks.
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The current Dresden Section 5.5 TS requires that reactivity limits for fuel I
storage be maintained within the limits specified in current TS Sections 3.10.G.1 and 3.10.G.2.
Proposed TS Section 5.6 does not include the specific reactivity limits specified in current TS Sections 3.10.G.1 and 3.10.G.2.
The proposed TS have moved the current reactivity limits concerning fuel storage to Section 9 of the UFSAR. The requirements outlined by the current TS Sections 3.10.G.1 and 3.10.G.2 are design parameters more appropriate for inclusions into the UFSAR and will be administratively controlled in owner controlled documentation. Changes to the reactivity limits will be controlled by 10 CFR 50.59.
The staff has determined that the requirements for fuel storage are not required to be in the TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act.
Further, they do not fall within any of the four criteria discussed in Section 2.0 above.
In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.59 to assure continued protection of public health and safety. The staff finds moving the current TS requirements of Sections 3.10.G.1 and 3.10.G.2 concerning reactivity limits to the USFAR is acceptable.
Proposed TS Section 5.6 adds specific design features concerning the drainage of the spent fuel pool and the capacity of the spent fuel pool for both Dresden and Quad Cities. The current ~ for Dresden and Quad Cities do not contain these design features.
Both new design features have been added to the proposed TS in accordance with the STS guidelines.
The proposed TS are consistent to the current Dresden and Quad Cities designs and do not reduce existing safety margins.
Therefore, the change from current TS is acceptable.
3.7 STS Section 5.7. Component Cyclic or Transient Limit STS Section 5.7 was not adopted in the proposed TS.
The current TS design feature sections for Dresden or Quad Cities do not contain Component Cyclic or
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Transient Limit requirements.
Design limits such as this are more i
appropriately controlled in owner-controlled documents. Currently, both Dresden and Quad Cities control the thermal cycle limits in the UFSAR.
Changes to the UFSAR are controlled by the requirements of 10 CFR 50.59. The staff finds this deviation from STS requirements acceptable.
3.8 Eglocation of Current TS Reauirements Current TS Section 5.6, which contains a discussion of seismic design, is proposed to be deleted. This parameter was not incorporated into STS requirements. This design parameter is considered to be adequately maintained i
and controlled in the UFSAR.
Changes to the seismic design criteria in the-UFSAR will be governed in accordance with 10 CFR 50.59.
The staff has determined that the requirements for seismic design are not required to be in the TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act.
- Further, they do not fall within any of the four criteria discussed in Section 2.0
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above.
In addition, the staff finds that sufficient regulatory controls exist j
under 10 CFR 50.59 to assure continued protection of public health and safety.
'Therefore, the staff finds the proposed deletion of the seismic design i
criteria from the TS is acceptable.
l 3.9 Open Items The following items should be left as open items, contingent upon l
implementation and correction in the TSUP clean-up amendment.
1.
Figure 5.1.B-1, Low Population Zone 2.
Figure 5.1.A-1, Exclusion Area 3.10 Summary for Section 5.0 The proposed TSUP TS Section 5.0, " Design Features," clarifies the requirements of the present TS through the adoption of STS format, adds more restrictive requirements, and incorporates changes to correct inconsistencies with the STS. The staff has reviewed the proposed TS against the STS and the current TS and finds that all deviations from the STS are acceptable and that the relaxation of current TS requirments does not reduce existing safety margins.
Based on the above evaluation, the staff finds the proposed TS 3
Section 5.0 is acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's. regulations, the Illinois. State official was notified of the proposed issuance of the amendments. The State official
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had no comments.
5.0 ENVIRONMENTAL 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 exposuce. 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 24909). 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.
6.0 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 Contributor:
J. Stang Date: June 14, 1995