ML20086E227
| ML20086E227 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/20/1991 |
| From: | Schrage J COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20086E228 | List: |
| References | |
| NUDOCS 9111270107 | |
| Download: ML20086E227 (23) | |
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44 * [\ Ccmm:nw:alth Edison 1400 opus Place
[( i vJ Downers Grove, Illinois 60515 O 1 l
November 20,1991 l Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk
Subject:
Ouad Cities Nuclear Power Station Units 1 and 2 Application for Amendment to Facility Operating Licenses DPR-29 and DPR-30, Appendix A, Technical Specifications Technical Specification Upgrade Program NRC_RockeLNos,ED:2542nd30 265 _
Reference:
R. Stols to T.E. Murley letter dated July 23,1991.
Dear Dr. Murley:
In 1990, Quad Cities Station initiated a formal program to enhance the Station's aerformance in various aspects of plant operation. The Performance Enhancement Program (PEP) was developed by assessing existing improvement plans, identifying potential weaknesses and prioritizing improvement actions. Necessary improvements to the Technical Specifications were identified as one of the Station's top priority issues. The Station developed a comprehensive Technical Specification Upgrade Program to address this issue. Details of the goal and methodology for the Technical Specification Upgrade Program are provided in the Executive Summary section of the proposed amendment. The Program has been previously discussed with members of the NRR staff.
As part of the Technical Specification Upgrade Program Commonwealth Edison Company submitted an Application for Amendment to Facility Operating Licenses DPR-29 and DPR-30, Appendix A, Technical Specifications, pursuant to 10 CFR 50.90 (referenced letter). This proposed amendment reflected Commonwealth Edison's efforts to upgrade existing Technical Specification 3.1/4.1, " Reactor Protection System". Subsequent to that submittal, Commonwealth Edison Company identified the need to revise the Application for Amendment.
The purpose of this letter is to submit a revised Application for Amendment to Facility Operatin Section 3.1/4.1,Reactorg Licenses DPR-29 Protection and DPR-30, System". This letterAppendix A, Technical and Application Specifications, for Amendment supercedes the referenced letter and associated application.
The revised application restores various channel calibration frequencies from Standard Technical Specification (STS) requirements to the current requirements, which are more conservative than STS. The restoration of the more conservative requirements are based upon historical drift data for the following Reactor Protection System instruments:
Reactor High Pressure, Drywell High Pressure, Turbine Condenser Low Vacuum, and Turbine EFlO Control Fluid Low Pressure.
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Dr. Thomas E. Murley November 20,1991 Please direct any questions concerning this proposed amendment to J, L.
Schrage at 708/515-7283.
Very truly you g, ohn L.
f chrage f
Nucle /(r Licensing Administrator Enclosure (A): Proposed Amendment to Technical Specification Section 3.1/4.1, " Reactor Protection System" cc: A.B. Davis, Regional Administrator L.N. Olshan, Project Manager T.E. Taylor, Senior Resident inspector Illinois Department of Nuclear Safety
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QUAD CITIES TECHNICAL SPECIFICATION UPGRADE PROGRAM t
The Quad Cities Technical Specification Upgrade Program was conceptualized in responce to lessons learned from the Dresden Diagnostic Evaluation Team inspection and the frequent need for Technical Specification interpretations. A
' comparison of the existing Quad Cities Technical Specification and, Standard Technical Specifications and later operating plants' Technical Specification provisions was conducted to identify potential improvements in clarifying requirements and to identify requirements which are no longer consistent with current industry practices.
5 The comparison review identified approximately one-hundred and fifty suggested improvements. The Technical Specification Upgrade Program was not intended to be a complete adoption of the Standard Technical Specifications.
Overall, the Quad Cities custom Technical Specifications provide a upgradefor safe was operation deemed of the plant and, therefore, only appropriate.
The comparison study revealed a mix of recommended upgrades which included the relaxation of certain existing Technical Specification requirements, the addition of surveillances, the removal of allowances which would no
' longer be allowed under new plant licensing, and better definition of appropriate action requirements in the event a Limiting Condition for Operation cannct be met. The Technical Specification Upgrade Program also implements NRC recommended line item improvements to the Technical Specifications Which were issued under Generic Letters.
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In response to an NRC recommendation, the Unit 1 and Unit 2 Technical Specifications are combined into one document. To accomplish the combination of the Units' Technical Specifications, a comparison of the Unit 1 and 2 Technical Specifications was performed to identify any
> technical differences. The technical differences are identified in the proposed amendment package for each section.
The Technical Specification Upgrade Program was fdentified as a Station top priority during the development
' of Quad Cities Station's Performance Enhancement Program (PEP) . The Technical Specification Upgrade Program's goal is to provide a better tool to Station personnel to implement their responsibilities and to ensure Quad Cities Station is operated in accordance with current industry practices. The upgraded specifications provide for more safe and reliable operation of the plant. The program improves the operator's ability to use the Technical Specifications by more clearly defining Limiting Conditions for Operations and required actions. The oost significant improvement to the specifications is the addition of equipment operability requirements during shutdown conditions.
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) EXECUTIVE SUMMABX (continuedl Proposed Changes to Technical Specification Bection 3.1/4.1, " Reactor Protection System" The present Quad cities Technical Specification contain J Applicability and Objr.ctive statements at the beginning of most sections. The proposed change provides each specification with a Limiting condition for operation (LCo),
Applicability, Action and Surveillance Requirement section, as applicable.
- The proposed changes to section 3.1/4.1 results in the consolidation and rearrangement of the instrumentation tables to present the information in a consistent and logical manner. Actions to be taken when required instrumentation is inoperable is provided following the LCO requirements.
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O, O SUMMEX QI q}IANGES PROPOSED SPECIFICATION 3.1/4.1 m
This amendment package is one in a series of proposals that will provide improvements to the present Quad Cities Technical Specifications. The summary of changes includes a general section to describe generic changes that are applicable to more than one section of the technical specifications and a section which
- () - provides the changes that are page by page specific.
GENERIC CHANGES Item 1:
The present Applicability and Objective statements at the beginning of each technical specification section are being
() deleted. The-Applicability statement is being included after the LCO statement in each individual specification.
Item 2:
Each specification is rearranged to follow an STS type of format Each specification
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C while retaining the present two column layout.
will contain an LCO, Applicability, Action and Surveillance Requirement section, as applicable.
Item 3:
n The instrumentation tables are rearranged to present the
information in a consistent and logical manner. The LCO requirements tables are rearranged to present in a left to right reading pattern for the columns of Trip Function, Minimum Operable Channels per Trip System, Trip Level Setting, Applicable Operational Modes, and Action. The Applicable Operational Modes column is added so that the user can easily ~ determine when the
(). instrumentation is required to be operable. Following the LCO requirements tables are the Actions to be taken when required instrumentation is inoperable and then the necessary Table Notations. Changes to the Surveillance Requirements Tables include rearrangement of the present columns where necessary to present a consistent.and logical format, deletion of the Group A, B. or C designation for instrumentation, and the addition of C Applicable Operational Modes consistent with the LCO requirements.
Item 4: ,
The Bases for each technical specification section is relocated to the end of the section.
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O O SPECIFIC CHANGES Item 1:
Pace 3.1/4.1-1. DPR-29 g Present Specification 3.1.A/4.1.A on the Reactor Protection System is modified as follows:
- a. Present LCO 3.1.A is rewritten to reference only Table 3.1-1. l l
Present Tables 3.1-1 through 3.1-4 are combined into Table 3.1-1.
O b. A new Applicability section is added to reference the ,
applicable Operational Modes in Table 3.1-1 for RPS instrumentation operability.
- c. A new Actions section is added to provide the action requirements that are applicable to all the RPS instrumentation. The instrument specific actions remain in
) Table 3.1-1.
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- d. New Surveillance Requirement 4.1.A.2 is added to specify testing requirements for RPS instrumentation response times.
Item 2:
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Paces 3.1/4 1-1 and 3.1/4.1-2. DPR-29 Proposed changes to present Specification 3.1.B/4.1.B and 4.1.C include the following:
) a. The title of APRM Scram and Control Rod Block Flow Biased j
Upscale Setpoints is added.
- b. An LCO statement is added as 3.1.B to reference Specifications 2.1.A.1 and 2.1.B for the APRM flow biased neutron flux upscale scram trip setpoint and the flow biased neutron flux upscale control rod block trip setpoint.
) c. An Applicability section is added to require these setpoints to be established when in MODE 1 with thermal power greater than or equal-to 25% of rated thermal power.
d.- New Actions are added to require compliance with the required j setpoints or initiate corrective action within 15 minutes and adjust the cetpoints to be consistent with the trip setpoints within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or reduce thermal power to less than 25% within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Provisions are retained from present specifications to allow adjusting the APRM gain instead of the setpoints.
) e. Present Surveillance Requirement 4.1.C is deleted. This I
o O testing requirement consists of requiring a functional test of all other RPS channels that monitor the same variable when a channel is failed in the unsafe condition. j Item 3: l
[) Engga 3.1/4.1-3 throuch 3.1/4.1-10. DPR-29 j
- a. Renumber the Bases pages to allow placement at the end of Section 3.1/4.1. j
- b. Delete the Bases for the APRM/IRM overlap function.
O c. In the Surveillance Requirements Bases, delete the description of the method used to determine the minimum functional testing frewency in accordance with Reference 1. Reference 1 is an outdated document and is no longer used to determine-surveillance testing intervals. Add a description of the methods currently used to determine surveillance testing g intervals.
- d. Add Bases changes to allow implementation of the proposed changes to the technical specifications.
Item 4:
Paces 3.1/4.1-11 throuch 3.1/4.1-11 DPR-29 O
- n. Combine present Tables 3.1-1, 3.1-2, and 3.1-3 into one Table 3.1-1. This combination will provide a single table containing an Applicable Operational Modes column instead of the present three tables, one each for the Refuel Mode, Startup/ Hot Standby Mode, and the Run Mode,
- b. The present columns for Table 3.1-1 are reordered such that the Trip Function is-the first column and the Minimum Operable Channels Per Trip System column is the second column.
- c. The Applicable Operational Modes are given as 1, 2, 3, 4 or 5.
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- e. The present requirements for the reactor _high pressure scram, the drywell high pressure scram, the reactor low water-level the main steamline high radiation scram, and the main scram,ine steaml isolation valve closure scrams to be operable in the O Refuel Mode are deleted from Table 3.1-1.
- f. Delete the present requirement in Table 3.1-2 for the Main steamline isolation valve closure scram to be operable in Startup/ Hot Standby.
- g. The Minimum operable Channels per Trip System for Turbine Stop v Valve Closure is change $ from 2 to 4.
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O h. Items 3a, 3b, 4b, and 4c of Table 3.1-1 are added to incorporate the STS provisions for " shorting links", for IRM and APRM Mode 5 requirements.
- 1. APRM High Flux (Scram Clamp) is added to Table 3.1-1, as item 4d. This provision is consistent with the STS provisions for C) Fixed Neutron Flux-Upscale and NEDC 30851P-A.
Item 5:
Pace 3.1/4.1-14, DPR-29 f3 The following changes'are made to the Notes for present Tables
3.1-1, 3.1-2, and 3.1-3.
- a. Present Note 2 contains the actions to be taken when the minimum operable channels requirement cannot be met for both trip systems. These present actions are moved from the Table Notes and are placed immediately behind new Table 3.1-1. New
() action requirements are added based on Standard Technical Specification (STS) requirements.
- b. Present Note 7 is deleted. This note states that the turbine condenser low vacuum scram and the main steamline isolation valve closure scram are automatically bypassed when reactor pressure is < 1060 psig.
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- c. Present Note 11 describes the APRM downscale trip function.
This note-is deleted with the deletion of the APRM/IRM overlap Trip Function.
- d. New Table Notes (a), (c), (g), (1), (m), and (n) are added.
C) Item 6:
Pace 3.1/4.1-15. DPR-29 The' changes to present Table 4.1-1 are'as follows:
() a. Change title to Table 4.1-1 to Reactor Protection System (Scram) Instrumentation Channel Functional Test and Channel Check Requirements.
- b. Delete the present column containing the Group'A, B, and C designations.
O- c. Add new columns for Applicable Operational Modes, Channel Functional Test and Channel Check. Add Modes to match operability requirements for Channel Functional Testing with operability requirements for the instruments in Table 3.1-1.
Change present column title Functional Test to Channel Functional Test Method.
C) d. Make changes to the surveillance intervals in accordance with 4
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O General Electric Topical Report NEDC-30851P-A. These changes will increase the functional testing for the Manual Scram from every 3 months to weekly. The present functional test l frequency of weakly for APRM High Flux (flow biased) is changed to within one week after entering Operational Mode 1 and quarterly thereafter. A new re@irement to functional test APRM High Flux (Scram Clamp), is added to provide
[) consistency between Table 3.1-1 and the surveillance tables.
Existing plant procedure requirements maintain this trip function at the same test frequency as APRM High Flux (Flow Bias). The present functional test frequency of once each week for APRM inoperative is changed to quarterly. The l present functional test frequency of before each startup for i IRM inoperative is deleted. Present functional testing
[O requirements for reactor high pressure, drywell high pressure, I
reactor low water level, turbine condenser low vacuum, main steamline high radiation, mein steamline isolation valve closure, turbine control valve fast closure, turbine stop valve closure and turbine EHC control fluid low pressure are
- ) changed to quarterly.
- e. Delete the APRM Downscale functional test requirement.
I f. Add new channel check provisions for IRMs and APRMs that are consistent with STS provisions. Retain the current l requirements for daily channel check of Reactor Low Water t
O Level and channel check of Main Steam Line High Radiation once per shift.
Item 7:
Page 3.1/4.1-16. DPR-29 I) The following changes are made to the Table Notes for Table 4.1-1.
- a. Delete present Note 1 pertainirg to an outdated method of determining surveillance frequency.
- b. Delete present Note 3 which references the three groups (A, B, and c) that are no longer being utilized.
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- c. Delete present Note 6 which requires testing frequency need not exceed weekly.
- d. Delete present Note 8 which specifies a functional test of the master and slave trip units monthly and a calibration of the 4 trip unit concurrent with the functional test,
- e. Add new Table Notes (b), (e), (g), (h), (i), (j), (k), and (1).
Item 8:
$ Eagg 3.1/4.1-17. DPR-29 e
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- a. Delete the column for Group A, B, and C. e
- b. Add-the Applicable Operational Modes column for Calibration testin to match operabilit requirements for the instruments
' in Tab e 3.1-1. Change "Ca ibration Test" terminology to
) " Channel Calibration."
c._ The Minimum Frequencies for IRM High Flux are changed from every controlled shutdown to every refueling outage, not to ,
exceed once per week, are consistent with STS provisions.
d .- -Present calibration-frequency of quarterly for Reactor High
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Pressure Dr and Turb1ne EHC ywellControl High Pressure, Fluid LowTurbine Condenser Pressure Low Vacuum, are retained.
- e. Present calibration frequency for Reactor Low Water Level of monthly for trip units concurrently with functional testing _is changed to quarterly in accordance with GE Topical Report
- f. Change the Calibration Test method for Reactor Low Water Level, Losslof-EHC Control Oil Pressure, Turbine Control Valve Fast Closure _and High Water Level in-Scram' Discharge Volume to Standard-Pressure Source.
} -9 Delete present-Note 1 concerning_the Group A, B, and C designations.
- h. APRM High Flux calibration requirements are changed to provide
-consistency between Table 3.1-1 and the surveillance requirement tables. APRM surveillance requirements are changed <to Flow Bias,-15% Scram-and Scram Clamp. The kez calibration method for these instruments has been changed to identify _these as electronic calibrations.-
- 1. Add-new Notes-(a), (d) ,- (g) , (1), (j) ,_ and - (k) .
j._ IIU4 calibration method is changed- to electronic calibration.
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DESCRIPTION OF CHANGES l 1
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,, DESCRIPTION QZ PROPOSED AMENDMENT REOUEST a
PROPOSED SPECIFICATION 3.1/4.1 REACTOR PROTECTION SYSTEM q The changes proposed in this amendment request are made to 1) improve the understanding and usability of the present technical specifications, 2) incorporate technical improvements, and 3) include some provisions from later operating BWR plants.
An item by item description of the proposed changes requested is provided below. The Summary of Changes section can be referred to 0 in order to reference back to a given change and its affected page.
GENERIC CHANGES Item 1 O The present Quad Cities tect.nical specifications contain Applicability and Objectivs statements at the beginning of most sections. These statemerus are generic in nature and do not provide any useful info.mation to the user of the technical specifications. The pcoposed change will delete the Objective statement and provide Applicability statements within each n specification similar to the STS. The proposed Applicability
'" statement to be incluited in each specification will include the Reactor Operational Modes or other conditions for which the LCO must be satisfied.
Itsm 1 sp The changes proposed in this item will provide an STS type of format while retaining the present two column layout. The present format does not provide a separation of LCO, Applicability, and Action requirements that are easily understood and identified.
j The two column layout has been utilized at Quad cities since initial licensing of the plant and is preferred by the plant over the single column STS layout.
393 1 The proposed rearrangement of the instrument tables will provide consistency in presentation of material and present the material in a fashion that is user friendly. The addition of the o Applicable Operational Modes column to the instrumentation tables
" will provide readily accessible information concerning when equipment is required operable and when surveillance requirements must be performed.
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Item 1 This item provides the relocation of the bases of the technical specifications from the present location of immediately following the LCO material to the end of the section. For sections with tables or figures, the tab 1cs and figures will now be located
() after the LCOs and before the bases. This change recognizes that the bases provide reference material which is of secondary importance to the other material in the technical specifications.
SPECIFIC CHANGES
() Item 1 Present LCO 3.1. A references Tables 3.1-1 through 3.1-4 for the setpoints, minirim number of trip systems, and minimum number of instrument channels that must be operable for each position of the reactor mode switch. The proposed change will combine these tables into one Table 3.1-1. Instead of a separate table for each
-(3 of the reactor modes of Refuel, Startup/ Hot Standby, and Run, the new Table 3.1-1 will contain a column for Applicable Operational Modes to indicate when the instrumentation is required to be operable. The use of a single table for this purpose will help to eliminate the possibility of using the wrong table to determine operability requirements and will implement a format similar to
'() later plants using the STS.
The proposed Applicability section in LCO 3.1.A is similar to STS L
requirements and references new Table 3.1-1 for operability requirements relative to reactor Operational Modes.
The proposed Actions section for LCO 3.1.A follows STS guidelines I) and implements allowed out of service times from General Electric Topical Re' port NEDC-30851P-A. Applicable footnote re@ irements
! from the STS have been incogorated into proposed Actions i and 3 l since the Quad Cities two column format does not make use of I footnotes at the bottom of the page.
,9 The present Surveillance Requirements for 4.1.A have been modified
? by the addition of 4.1.A.2. The new Surveillance Requirement i provides definitive provisions for testing system response times j
of the reactor protection system in accordance with STS -
guidelines.
I DA r) s.
Present Specification 3.1.B/4.1.B does not have a separate title within the Reactor Protection System Specification. The proposed change will add the title of APRM Scram and Control Rod Block Flow Biased Upscale Setpoints consistent with the subject matter of the L specification.
O The proposed LCo for 3.1.B is similar to the present specification
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O, e since both reference Specifications 2.1.A.1 and 2.1.B for APRM and
^3 rod block settings. The proposed Applicability section is similar to present requirements by requiring operability only in Operational Mode 1 when thermal power is greater than or equal to 25% of rated thermal power.
() The proposed Actions for 3.1.B are more restrictive than present requirements since time frames for accomplishing the actions-are specified similar to STS provisions. The proposed actions require that with the APRM flow biased neutron flux upscale scram trip setpoint and/or the flow biased neutron flux upscale control rod block trip setpoint less conservative than the value shown in the equations in Specifications 2.1.A.1 and 2.1.B, corrective action O must be initiated within 15 minutes and setpoints adjusted to be consistent with the trip setpoint values within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or thermal power must be reduced to less than 25% within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Provisions for adjusting the APRM gain, instead of the setpoints, are included as in the present specifications.
n Present Surveillance Requirement 4.1.C provides additional testing
's provisions for RPS channels when it is determined that a channel is failed in the unsafe condition and the minimum operable channels per trip system requirement cannot be met. This additional functional testing requirement is not necessan to determine operability of the remaining channels and most likely will not provide any useful information concerning a potential
() common cause failure. The plant evaluates instrumentation
, failures as they occur including the potential for common cause
! failure of other similar equipment. Present Surveillance l Requirement 4.1.C is deleted by these proposed changes.
Item 2 O This item relocates the present Bases for 3.1/4.1 to the end of the section. This move will place the most important information first and make this information more readily accessible to the user. The changes to the present Bases include the deletion of the discussions for the APRM Downscale scram and deletion of the outdated methods described to determine the minimum functional testing frequen y in a rdance with Reference 1. The technical O discussion for deletion of the APRM Downscale scram is provided-below. Other changes to the Bases are necessary to allow l implementation of the changes described in this submittal.
l l Item 1
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This item contains the proposed changes to Tab?cs 3.1-1, 3.1-2, and 3.1-3. Presently, three tables are providta for listing the RPS instrumentation requirements, one table each for the Refuel, Startup/ Hot Standby, and Run modes. The progssed change will combine the three tables into one by adding an Applicable Operational Modes column as Modes 1, 2, 3, 4 or 5 corresponding to the Operational Mode definitions proposed in Table 1.2. The use
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) of one table instead of three will provide a more user friendly format and help to eliminate the possibility of looking at the wrong table for RPS instrumentation operability requirements.
The present order for the columns in Tables 3.1-1 through 3.1-3 is changed such that the Trip Function is first andThis the Minimum change is operable Channels per Trip System is second.
proposed in order to make the tables more user friendly since the Trip Function is the first item looked for in these tables before looking for operability information.
The proposed Applicable Operational Modes for Table 3.1-1 are 1, 2, 3 4, or 5. The proposed instrumentation operability requirements ensure availability of the scram trip functions in g
operational Modes where the scram may be necessary.
APRM Downscale Deletion The APRM Downscale Scram existed on several early BWR plants including Dresden Units 2 and 3 and Quad Cities Units 1 and 2. It 3 was deleted by General Electric on later BWRs because it was not seen as performing any function commensurate with its required surveillance. In consideration of this surveillance difficulty, and the doubtful contribution which was made to the overall neutron monitoring protection system, GE decided to eliminate the APRM Downscale Scram on later plants. The APRM Downscale Scram
] has already been deleted from the Dresden Technical Specifications and has been evaluated by GE and found to be unnecessary for the Quad Cities plant. Removal of the APRM/IRM companion scram eliminates the.APRM downsccle scram which occurs in the Run The mode with the simultaneous IRMs ";.igh high" or inoperable.
accidents of concern with respect to the APRM/IRM companion scram are the Rod Drop Accident (RDA) and the low power Rod Withdrawal FSAR and reload safety analyses do not credit this h
Error (RWE) scram funct ion in the termination of either of these accidents.
The limiting accidents (i.e., RDA and RWE) in the operating region l
of transition between the Startup and Run-Modes are well understood and are evaluated in FSAR and/or reload safety analyses. Elimination of the APRM Technical Specification requirement for the downscale/IRM "high hi ha or inoperable trip 3 does not introduce any new accident scenar o since it is not credited in the termination of these limiting events. Other control rod initiated events which are less limiting in this region, such as fast period events (either due to operator error or CRD malfunction), are subsets of the low power RWE event and are bounded by both it and the Design Basis RDA. General Electric has indicated that, for reactivity insertion mechanisms at very
] low power (if postulated to occur coincident with an inappropriate mode switch position), the only effect of the deletion of the APRM downscale scram would be that the initial power level could be a few percent lower which would not have a significant effect on the severity of the event. In addition, proper overlap between the IRMs and APRMs is not affected since the calibration requirements
) are not being changed.
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l O Present Table 3.1-1 contains operability requirements for RPS Instrumentation for the Refuel mode. The proposed changes will delete operability requirements in the Refuel mode for the reactor high pressure scram, the drywell high pressure scram, the reactor low water level scram, the main steamline high radiation scram, and the main steamline isolation valve closure scram. In the C) Refuel node, interlocks are in place so that one control rod only may be withdrawn when flux amplifiers are set at the proper sensitivity level and the refueling crane is not over the reactor.
In the Refuel mode the trips from the turbine control valves, turbine stop valves, main stet.line isolation valves, and In the Refuel mode, scrams from condenser vacuum are bypassed.
g, reactor high pressure and drywell high pressure are not needed due V to the unlikely occurrence of high pressure in this mode of operation. Also due to the limitation on control rod withdrawal in the Refuel mode, scram signals from reactor low water level and main steanline high radiation are not required to perform a mitigating function.
() Present Table 3.1-2 requires the main steamline isolation valve closure scram to be operable in the Startup/ Hot Standby mode.
This signal is bypassed in the Startup/ Hot Standby mode and is being deleted from Table 3.1-2 and will not be included in new Table 3.1-1.
The Minimum Operable Channels per Trip System requirement for the
.,s v Turbine Stop Valve Closure Scram is being changed from 2 to 4.
This change is being made to clarify system rewirements and to prevent possible misinterpretation of operability requirements.
The present design incorporates one limit switch per valve with each limit switch actuating two contacts (two channels of trip signals), one for each trip system. The change to four Minimum Operable Channels per Trip System reflects the actual number of
- c)
'- channels installed in the plant and will help to ensure that proper Action is taken if a channel is inoperable.
The STS provisions to remove " shorting links" prior to and during shutdown margin demonstrations are incorporated into the Mode 5 requirements for IRMs and APRMs.
O APRM High Flux (Scram Clamp) is added to be ccasistent with STS Fixed Neutron Flux-Upscale provisions.
Item 1 The present Notes for Tables 3.1-1 through 3.1-3 contain both I) Notes and Actions to be taken if instrumentation requirements are not met. The proposed change will separate the Notes and the Actions such that Action requirements are easily discernable and are on a separate page following the applicable table. New Action requirements are added based on STS provisions and are needed to address the-addition of the new modes of operation added to the m
table as well as to implement requirements found acceptable for d use at STS BWRs. The present Action allowance of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to reach
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D Startup is retained in the now requirements in order to allow for an orderly plant shutdown from the full power, 100% rod pattern.
Present Note 7 for Tables 3.1-1 through 3.1-; is deleted by the proposed changes. This note states that the turbine condenser low vacuum scram and the main steamline isolation valve closure scram are automatically bypassed when reactor pressure is < 1060 ps19 .
D The actual bypass of the functions is based on Reactor Mode Switch position and thus Note 7 is not needed.
Present Note 11 describing the APRM/IRM overlap trip is being deleted since as described above, the APRM Downscale trip is being deleted.
D New notes (a), (c), (g), (i) , (m), and (n) are added to proposed Table 3.1-1 in order to provide information similar to that contained in STS plant versions. Proposed note (a) implements an out of service time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> consistent with changes proposed in General Electric Topical Report NEDC-30851P-A.
D Iten 1 Item 6 involves proposed changes to present Table 4.1-1 on Scram Instrumentation Channel Functional Tests and Channel Check 3, and C Requirements. The column containing Group A, designations is deleted since it is not being utilized. A new column for Applicable Operational Modes is added to provide E consistency between Table 3.1-1 and the Surveillance Requirements Tables. The terminology " Functional Test" is changed to " Channel Functional Test" to be consistent with proposed Definition 1.6. A new column for channel check requirements is added. Channel checks for IRMs and APRMs are added to be consistent with STS provisions, while the current requirements for channel check of Reactor Low Water Level, 9aily, and Mhin Steam Line High B Radiation, once each shift, are retait'ed.
New channel functional test and channel check provisions are added for Pfgh Flux (Scram Clamp). These repirements are consistent with existing plant procedures to require APRM High Flux (Scram Clamp; functional testing within one week after entering D Operational Mode 1 and quarterly thereafter as supported by NEDC 30851P-A. The channel check provisions of STS, APRM Fixed Neutron Flux-Upscale are incorporated as proposed channel check provisions for APRM High Flux (Scram Clamp).
Another change to Table 4.1-1 implements surveillance intervals in accordance with General Electric Topical Report NEDC-30851P-A.
I The proposed changes are in some cases more conservative The and in some cases less conservative than present' requirements.
overall affect on RPS reliability and availability was evaluated using the proposed surveillance testing intervals and the methodology of the Topical Report. The following surveillance frequency changes are proposed:
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- a. Change the manusi scram functional test frequency from every 3 months to weekly,
- b. Change the APRM high flux scram functional test frequency i from once each week to within one week after entering Operational Modes 1 and quarterly thereafter.
- c. Change the APRH im, perative and main steamline high radiation scram functional test frequency from once each week to quarterly.
- d. Change the reactor high pressure, dryvell high pressure, reactor low water level, turbine condenser low vacuum, main steamline isolation valve closure, turbine control f valve fast closure, turbine stop valve closure, and turbine EHC control fluid low pressure scrams from in accordance with Note 1 to quarterly.
Note that present Hote 1 to Table 4.1-t silows the functional test frequency for the affected parameters to be extended to quarterly using an outdated methodology which is being deleted by the changes proposed in this amendment request. Also, it should be noted that the " Trip Level Settings" listed in proposed Table 3.1-1 are limiting setmoints shich are equivalent to " Allowable Values" in the STS. Tae actual plant setpoints are conservatively adjusted with respect to the Technical Specifications " Trip Level
) Settings" to accommodate the drift associated with the particular instrument and test interval. As such, revised results c(
instrument setpoint calculations required to accommodate the longer test intervals may result in changes to actual plant setpoints, but will not require further Technical Specification changes.
) Commonwealth Edison Company participated in the BWR Owner's Group effort that produced Topical Report NEDC-30851P-A. As such, plant specific analyses were performed to identify the differences between the parts of the RPF that perform trip functions in the Quad cities plant and those of the base case plant analyzed in HEDC-30851P-A. These differences were analyzed and found to be j acceptable or to be bounded by the base case. The additional time interval between tests resulting from the changes described in NEDC-30851F-A will be factored into the instrument setpoint calculations for the affected instruments. If the setpoint the setpoints will b4 conservatively calculations so indicate,he adjusted to accommodate t additional drift associated with the
, longer test interval or the test interval will not be extended..
) The present functional test fre@ency of before each startup for IRM inoperative is deleted. This change provides consistency with STS provisions and deletes an unnecessary test requirement. The prior to startup test requirement for IRM High Flux and the weekly
' functional test of the IRM Inoperative while in operational Modes 2, 3, 4, or 3 remains in the Technical Specifications to ensure IRM operability when required.
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I O The APRM Downscals functional test requirements ato deleted in i conjunction with the deletion of the APRM Downscale Trip Function as described above in Item 4.
j Item 2 i l ltem 7 involves changes to the Notes for Tabic :-1. ? resent O Note 1 is deleted since this outdated methodolos 'ot .tetermining j surveillance intervals is no longer utilized. Prs , Note 3 which references Groups A, B, and C is deleted since the groups are no longer utilized. Present Note 2 is deleted and the l
4 requirements to channel check RPS instruments are outlined under the new Channel Check column of Table 4.1-1. New Notes (b), (e),
2 (g), and (1) are added to the table and are modeled after STS
- 5) provis(h),
ions. Proposed Noto (1 clarifles testing requirements for l
4 the APRM High Flux (flow biase)d) and APRM High Flux (Scram Clamp)
Trip Functions such that present plant testing methods of within one week after entering Operational Mode 1 are not misunderstoed.
- Proposed Note (j) is added to Table 4.1-1 to provide consistent operability exceptions with those in Tables 3.1-1 and 4.1-2.
Proposed Note "O of Specificatio(k) allowssuch n 4.0.D a necessary exception that Operational to 2the Mode provisions can be entered from Operational Mode 1 and sufficlont time allowed, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, to 4
perform the Channel Functional Test for the IRM High Flux and Inoperable Trip Functions.
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4 The proposed changes to Table 4.1-2 and related Notes are
- described in this item. The present column in Table 4.1-2 designating Groups A, B, and C is deleted as in Table 4.1-1 above.
The Applicable Operational Modes Column is added to the Table to indicate the conditions when the calibration requirements must be g met.
Changes in the Trip Function column listings for APRM High Flux are mada to provide consistency betwoon Table 3.1-1 and the surveillance requirement tables. Current requirement, APRM High Flux-Output Signal is deleted, and 15% Scram and Scram Clamp are '
added. The proposed minimum frequencies for these trips are O- consistent with STS provisions for APRM Neutron Flux-Upscale, Setdown and Fixed Neutron Flux-Upscale respectively. The Chan:!cl Calibration Methods for 1RM High Flux, APRM High Flux 15% Scram and APRM-Scram Clamp are changed to electronic calibration to clarify and incorporate current plant procedures into the Technical Specifications. These provisions are consistent with the STS provisions for neutron measurement systems in other V, plants.
The calibration frequency for IRM High Flux is changed to the STS provisions of every refueling for Modes 2, 3, 4, 5. The present calibration frequencies of quarterly for Reactor High Pressure, Drywell High Pressure, Turbine condenser Low Vacuum, and Turbine O EHC Control Fluid Low Pressure Trip Functions'are retained. The 0
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O present Calibration Standards for the Reactor Low Water Lovel and Scram Discharge Volumo High Water Levol is listed as Water Lovel and for the Loss of EHC Control Oil Pressure and Turbino Control Valve Fast Closure as Pressure Source. The proposed chango will i
list the channel calibration Method as Standard Pressure source for all four of those Trip runctions. This change in terminology is made to clarify present requirements without changing any
.O present testing motiods or intent.
Prosent Note 1 concerning the Group A, B, and c designations is doloted as in Table 4.1-1 above. Now Noto is added to point out that neutron detectors, due to location (a)and design are excluded from calibration. New Note (g) is added by transferring the frequency of-test for the LPRMs from the table column to the O Notes. This change is made because the frequency of test is ovary 1000 equivalent full power hours which does not fit the now Surveillanco Frequency designations proposed in Tablo 1.1. New notes (d) wookly and (k calibratio)ns.are consistent with STS provisions Proposed Notes (1) and (j) arefor APRM added to Table 4.1-2 to provido consistent operability exceptions with
() those in Tables 3.1-1 and 4.1-1.
Analog Trip System (ATS), trip function, present Note 7 requires For the Reactor Low Water Lovel, trip units to be calibrated monthly concurrently with functional testing and that transmitters be calibrated onco por operating cycle. Present Note 7 is rewritten as Note (e) and revised to require trip units to be calibrated quarterly consistent with the changes proposed for Table 4.1-1.
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