ML20098A345
| ML20098A345 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 09/20/1995 |
| From: | Schrage J COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20098A346 | List: |
| References | |
| NUDOCS 9509250067 | |
| Download: ML20098A345 (14) | |
Text
I Commonwcalth litnon Oimpany I 600 Opua Pixe Dow ncrs Gros e, II. 60515
- o September 20,1995 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk
Subject:
Quad Cities Nuclear Station Units 1 and 2 Application for Amendment to Facility Operating Licenses DPR 29 and DPR-30, Appendix A, Technical Specifications for Technical Specification Upgrade Program NRC Docket Nos. 50-254 and 50-265
References:
(1)
J. Schrage to T. Murley letter dated October 2,1991 (2)
J. Schrage to USNRC letter dated September 1,1995 in 1991, Commonwealth Edison (Comed) initiated a formal program to enhance Quad Cities Station's performance in various aspects of plant operation. Necessary improvements to the Technical Specifications were identified as one of the Station top priority issues. In support of that effort, Quad Cities submitted revised Technical Specifications to the NRC during the course of the year (the Reference (1) letter included Quad Cities' submittal for Section 6.0]. To enhance the Quad Cities effort and to improve the Technical Specifications at Dresden Station, Comed initiated a combined, two-station, Technical Specification Upgrade Program (TSUP) to revise the Dresden Technical Specifications and improve the Quad Cities submittals. This program has been outlined and discussed with members of the NRR staff.
Pursuant to 10 CFR 50.90, Comed proposes to amend Appendix A, Technical Specification to Facility Operating Licenses DPR-29 and DPR-30. The proposed amendment reflects Commonwealth Edison's efforts to upgrade existing Quad Cities Station Units 1 and 2 Technical Specification Section 6.0 " Administrative Controls." An overall description of the proposed amendment is also included in the Executive Summary. Comed provided a similar proposed amendment for Dresden Station Units 2 and 3 in Reference (2). This proposed amendment for Quad Cities Station Units 1 and 2 supersedes the Reference (1) submittal for Section 6.0,
" Administrative Controls."
The proposed amendment request is provided as follows:
1.
An Executive Summary of the Technical Specification Upgrade Program and the proposed amendment; 2.
A description of the proposed amendment; 3.
The proposed Technical Specification pages with the requested changes; I
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U.S. NRC September 20,1995 4.
The existing Technical Specification pages for DPR-29 and DPR-30 (Quad Cities).
To reduce the administrative requirements to process this amendment package, a list of the deleted page= for Quad Cities Station Units 1 and 2 are provided; 5.
The technical differences between the existing Quad Cities Unit 1 and Unit 2 Technical Specifications; and 6.
Commonwealth Edison's evaluation pursuant to 10 CFR 50.92(c) and 10 CFR 51.21; The proposed amendments have been approved by Commonwealth Edison's On-Site and Off-Site Review in accordance with Company procedures.
The Technical Specification Upgrade Program (TSUP) proposes changes to each section of the existing Technical Specifications. As such, Commonweahh Edison requests that the proposed amendments be approved as submitted but to become effective upon completion of the entire project. It is requested that the proposed changes to Section 6.0 be approved prior to November 3, 1995.
To the best of my knowledge and belief, the statements contained are true and correct. In some respects, these statements are not based on my personal knowledge but obtained information furnished by other Commonwealth Edison employees and consultants. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Commonwealth Edison is notifying the State of Illinois of this application for amendment by transmitting a copy of this letter and its attachments to the designated State Official.
If there are any comments or questions concerning this submittal, please direct them to this office.
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Attachments:
1.
Executive Summary 2.
Description of the Proposed Amendment 3.
The proposed Technical Specification Pages 4.
Listing of Deleted Technical Specification Pages
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5.
Technical Difference Matrix 6.
Significant Hazards Evaluation and Environmental Assessment H.J. Miller, Regional Administrator - RIII cc:
J.F. Stang, Project Manager - Dresden R.M. Pulsifer, Project Manager - Quad Cities M.N. Leach, Senior Resident Inspector - Dresden C.G. Miller, Senior Resident Inspector - Quad Cities Office of Nuclear Facility Safety - IDNS k:\\nla\\ quad \\ciup\\60_cov.wpf
ATTACHMENT 1 EXECUTIVE
SUMMARY
" ADMINISTRATIVE CONTROLS" k:\\nla\\ quad \\tsup\\60_att2.wpf
1 I
EXECUTIVE
SUMMARY
w The Technical Specification Upgrade Program (TSUP) was conceptualized in response to lessons -
learned from the Dresden Diagnostic Evaluation Team inspection and the frequent need for.
Tecimical Specification interpretations. A comparison study of the Standard Technical Specification (STS), later operating plant's Technical Specifications provisions and Quad Cities Technical Specifications was performed prior to the TSUP effort. The study identified potential -
improvements in clarifying requirements and requirements which are no longer consistent with current industry practices, i
The TSUP is not intended to be a complete adoption for the STS. Overall, the Quad Cities custom' Technical Specifications provide for the safe operation of the plant and therefore, only an upgrade is deemed necessary.
~
j In response to an NRC recommendation, Quad Cities combined the Unit 1 and Unit 2 Technical l
Specifications into one document. To accomplish the combination of the Units' Technical Specification, a comparison of the Unit 1 and Unit 2 Technical Specification was performed to.
- identify any technical differences. The technical differences are identified in the proposed amendment package for each section.
L The TSUP goal is to provide a better tool to station personnel to implement their responsibilities and to ensure that Quad Cities Station is operated in accordance with current industry practices, i
The improved Technical Specifications provide for enhanced operation of the plant.
The proposed TSUP.Section 6.0 requirements are consistent with those proposed in Comed's April
. 24,1995 submittal. The proposed changes are as follows: 1) deletion of the " Review, Investigative i
- and Audit Functions"; 2) title changes to reflect the reorganization of Comed's Nuclear Operations l
Division; 3) miscellaneous administrative and editorial changes.
The proposed specifications are based upon the Byron and Braidwood Technical Specifications. The proposed specifications utilized the Byron /Braidwood specifications because they more closely follow the Standard Technical Specifications. Specification 6.0 has been reordered and new titles have been added based on STS arrangements and nomenclature. Some sections have moved to be i
consistent with the Byron and Braidwood Technical Specifications.
t i
Current Specifications 6.7, " Environmental Qualification" and 6.10, " Major Change to Radioactive Waste Treatment Systems" are deleted in accordance with Standard Technical Specifications.
l Section 6.7 has been superseded by 10CFR 50.49 and Section 6.10 was deleted through the l
implementation of Generic Letter 89-01, t
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ATTACHMENT 2 1
DESCRIPTION OF CHANGES Technical Specification 6.0
" ADMINISTRATIVE CONTROLS" k:\\nla\\ quad \\tsup\\60_att2.upf
ATTACHMENT 2 DESCRIPTION OF AMENDMENT REQUEST 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 plants.
GENERIC CHANGES The format of the proposed TSUP specification is adopted from the Byron and Braidwood Technical Specifications. The proposed format changes are to make TS Section 6.0 consistent among all of Comed's six nuclear stations. The proposed specifications utilized the Byron /Braidwood specifications because they more closely follow the Standard Technical Specifications. Therefore, the proposed specifications are identical to the approved Byron and Braidwood Technical Specifications except where limited by design or station procedural practices.
COMPARISON OF CURRENT TECHNICAL SPECIFICATIONS (CTS) TO TSUP AND BASIS OF THE PROPOSED CHANGES CTS 6.1 Organization, Review, Investigation and Audit 1.
CTS 6.1.A.1 is encompassed within TSUP 6.2.A.1. The proposed deletion of CTS 6.1.A.1 requirement "... or the Management Plan for Nuclear Operations, Section 3 Organizational Authority, Activity; Section 6 Interdepartmental Relationships." is consistent with Comed's submittal dated April 24,1995. The Management Plan is no longer maintained, therefore, this reference has been deleted. The Organizationallines of authority and responsibilities will continue to be documented in the QA Manual. Maintaining these requirements in the QA Topical Report will ensure that proposed changes to these requirements will receive appropriate internal review and regulatory oversight. NRC review of the Quality Assurance Program is governed by 10 CFR 50.54, 2.
CTS 6.1.A.2 is encompassed within TSUP 6.2.A.2. The proposed requirements are equivalent to CTS requirements.
3.
CTS 6.1.A.3 is encompassed within TSUP 6.2.A.3. The title " Senior Vice President -
Nuclear Operations" has been changed to " Chief Nuclear Officer (CNO)" to be consistent with the current corporate management structure at Comed. The proposed change is consistent with Comed's submittal dated April 24,1995.
4.
CTS 6.1.A.4 is encompassed within TSUP 6.2.A.4. The proposed requirements are equivalent to CTS requirements.
5.
CTS 6.1.B is encompassed within TSUP 6.2.B.S. Minor administrative changes to the titles of key personnel are proposed to be consistent with current plant terminology. " Licensed Senior Operators" has been modified to " senior reactor operators". " Licensed operators" has been modified to " reactor operators". " Health physics personnel" has been modified to
" health physicists", " Equipment operators" has been modified to " auxiliary operators".
6.
CTS 6.1.C is encompassed within TSUP 6.2.B. Several title changes are proposed to reflect the current Quad Cities organization. The Maintenance Assistant Superintendent has been changed to Maintenance Superintendent. The Shift Foreman title has been changed to Shift k:\\nla\\ quad \\tsup\\60_att2.wpf
-1
ATTACHMENT 2 Supervisor. The Station Control Room Engineer (SCIG) has been eliminated; however, minimum shift manning requirements are unaffected. A new position called Unit Supervisor has been added. The Unit Supervisor is an SRO normally assigned as an SRO in the control room. The Unit Supervisor has replaced the Shift Foreman as one of the positions requiring a senior operator's license. The requirements of CTS Figure 6.1-3, specific to the minimum licensed operator staffing levels during CORE ALTERATIONS, are not included in TSUP because they are encompassed within 10 CFR 50.54(m)(2)(iv). Per Operating Licenses DPR-29 and DPR-30, Quad Cities must satisfy the requirements of to CFR 50.54(m)(2)(iv).10 CFR 50.54(m)(2)(iv) specifies that "Each licensee shall have present, during alteration of the core of a nuclear power unit (including fuel loading or transfer), a person holding a senior operator license or a senior operator license limited to fuel handling l
to directly supervise the activity and, during this time, the licensee shall not assign other duties to this person." As such, Technical Specification requirements for the minimum licensed operator staffing levels during CORE ALTERATIONS are redundant. Therefore, the proposed change administratively relocates the description of these controls and does not relax the plant's obligations to maintain the appropriate licensed operator staffing levels during CORE ALTERATIONS. The proposed change is consistent with Comed's submittal dated April 24, 1995.
The requirements of CTS Figure 6.1-3 are encompassed within TSUP 6.2.B,6.2.C and 10 CFR 50.54(m)(2)(i).10 CFR 50.54(m)(2)(i) specifies the number of Operators and Senior Operators required per shift and is dependent upon the operating mode of the Units. Per Operating Licenses DPR-29 and DPR-30, Quad Cities must satisfy the requirements of to CFR 50.54(m)(2)(i). With neither unit operating, one senior operator license and two operator licensed personnel are required to be on-shift. With one or both units operating, I
two senior operator licenses and three operator licensed personnel are required to be on-l shift. TSUP 6.2.C provides additional requirements and role clarification for the STA. The proposed change is consistent with the shift manning requirements as discussed in the Improved Standard Technical Specifications (ITS - NUREG-1433, Revision 1). The reference to 10 CFR 50.54(m)(2)(i) within proposed TSUP 6.2.B.3 ensures that the appropriate shift-manning requirements are maintained. Therefore, the proposed changes administratively relocates the description of these controls and does not relax the plant's obligations to maintain the appropriate licensed operator staffing levels on-shift.
7.
CTS 6.1.D is encompassed within TSUP 6.3. The position of Technical Superintendent no longer exists. The requirement that the individual filling the position of Site Engineering l
Manager meets the requirements for Technical Manager as described in Section 4.2.4 of ANSI N18.1 (1971) is redundant to existing requirements for unit staff and has been deleted.
The title Health Physics Services Supervisor has been changed to Rad / Chem Superintendent to reflect the current station organization. The remainder of the proposed change is consistent with Comed's submittal dated April 24, 1995. For administrative controls of the Fire Protection Program see the discussion for CTS 6.1.E.
The specific details regarding the training of Radiation Protection Technicians has not been q
retained within TSUP 6.3. The requirements specified in ANSI N18.1 should suffice for defining the training requirements for site personnel. The specific procedural details for delineating the training program for personnel is inappropriate for inclusion within the Technical Specifications as this information is more appropriately contained within station procedures, controlled by 10 CFR 50.59.
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o ATTACHMENT 2 8.
CTS 6.1.E (retraining and replacement training) has been retained within TSUP 6.4. The proposed TSUP changes relocate the requirements for the fire brigade training and other fire protection administrative controls to the Fire Protection Program, as described in the station's UFSAR. Current license condition 3.F for Quad Cities Units 1 and 2 provides adequate controls of these requirements. This control ensures that any changes made to the station's fire protection program that adversely affect the ability of the plant to achieve and maintain safe shutdown in the event of a fire, require NRC staff review and apporval. As such, the current license conditions provide an equivalent level of oversight as the current Section 6.0, Administrative Controls and are therefore, redundant. Because, the relocation of these requirements to the UFSAR does not reduce the controls of existing requirements; as such, the proposed change is administrative in nature and does not reduce existing plant fire protection requirements.
9.
CTS 6.1.F has not been retained within TSUP 6.4. The proposed training and re-training requirements for site personnel (iicensed and unlicensed) are adequately controlled via the provisions of ANSI N18.1 or by the licensing requirements of the individual's licenses. As such, the requirements specified in CTS 6.1.F are redundant and unnecessary for inclusion in the TS.
10.
CTS 6.1.G has not been retained within TSUP 6.0. The requirements contained in this section will be relocated to the Comed Quality Assurance Program Topical Report CE-1-A.
The proposed change is consistent with Comed's submittal dated April 24, 1995.
11.
CTS Figure 6.1-3 is encompassed within TSUP 6.2.B. The CTS requirement of Figure 6.1-3 pertaining to " Rad. Prot. Man" has been relocated to TSUP 6.2.B.3. The prc, posed requirements eliminate the ambiguities associated with the applicable conditions for manning of the Radiation Protection Technician. Current Technical Specification requirements are unclear regarding applicability and corresponding location of fuel within the nuclear units. Current Dresden provisions spccify in Table 6.1.1, " UNITS WITH FUEL" Current Quad Cities provisions specify in portions of Figure 6.1-3, "No Fuel in Second Unit." It is unclear if the current reference to fuel regarding the unit is applicable when fuel is in the reactor vessel or when fuel is in the reactor vessel and/or spent fuel storage locations. The proposed requirements explicitly clarify that the manning requirements are applicable for the Radiation Protection Technician when fuel is in the reactor, thus eliminating the current ambiguity.
The proposed requirements specified in TSUP 6.2.B.4 are consistent with those specified in the Improved Standard Technical Specifications (ITS - NUREG-1433). In addition, the proposed requirements are consistent with the provisions specified in the LaSalle County, Braidwood, Byron, River Bend, Perry and Hope Creek Technical Specifications.
l The proposed requirements enhance guidance given to shift personnel regarding minimum staffing levels and eliminate ambiguities associated with the current Technical Specification requirements; therefore, the proposed changes provide an adequate level of protection for Radiation Protection Technician shift manning when compared to curren requirements.
The Shift Engineer (SE) position fulfills the requirements in CTS for the mmber of SROs on shift. As such, the proposed TSUP requirements are equivalent to CTS shift manning requirements for SROs.
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ATTACHMENT 2 12.
CTS 6.1.H, regarding the Fire Protection Program, has not been retained within TSUP 6.0.
The requirements contained in this section will be relocated to the Comed Quality Assurance Program Topical Repon CE-1-A. This change is consistent with Comed's submittal dated April 24,1995.
CTS 6.2 Procedures and Programt 1.
CTS 6.2.A, regarding the controls for written procedures, is encompassed within TSUP 6.8.A. The proposed requirements are equivalent to CTS requirements.
2.
CTS 6.2.B, regarding technical review and control of procedures, and CTS 6.2.C, regarding temporary changes to procedures, have been deleted from TSUP and relocated to administrative controls. Relocation is based on existing regulations and standards that contain these provisions, such that duplication in TSUP is not necessary. The requirements for the extablishment, maintenance and implementation of procedures related to activities affecting quality are contained in 10 CFR 50, Appendix B, Criteria II and V; ANSI N18.7-1976; and ANSI N45.2-1971. Changes to the implementing procedures will be controlled by the requirements of 10 CFR 50.59 to ensure that prc,per reviews affecting safe operation of the plant are performed.
3.
CTS 6.2.E has not been retained within TSUP 6.0. The GSEP Manual requirements are encompassed within CTS 6.2.A.4, which specifies that written procedures shall be established, implemented and maintained covering the activities associated with the implementation of the Generating Station Emergency Response Plan. CTS 6.2.A.4 is retained as TSUP 6.8.A.4. In addition, the proposed changes are consistent with the requirements specified in the Byron /Braidwood Technical Specifications.
CTS 6.3 Renortable Event Action 1.
CTS 6.3 has not been retained in TSUP 6.0. Requirements regarding prompt reponing and reviewing of reponable events has not been retained in TSUP 6.0 The organization and responsibilities of individuals and functions are adequately described in plant procedures and the Quality Assurance Program. Eliminating repetition of these details from the Technical Specifications will not compromise plant safety. The removal of these items is consistent with changes addressed in NRC letter from W. T. Russell to Owners Group Chairmen, dated October 25,1993. In addition, the proposed changes are consistent with the guidance provided in the BWR Improved Standard Technical Specifications, NUREG-1433.
CTS 6.4 Action to be Taken in the Event a Safety Iimit is Exceeded 1.
CTS 6.4, regarding administrative actions required in the event a safety limit is exceeded, is encompassed within TSUP 6.7. CTS 6.4 nomenclature related to the Vice President BWR Operations being promptly notified of the event has been replaced with the Site Vice President to reflect current Comed organizational structure.
CTS 6.4, regarding the incident report development, has been encompassed within TSUP 6.7.A.2. TSUP provides clarification of the reporting vehicle for the event in that it requires an LER be prepared and submitted to the Commission to document the incident.
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ATTACHMENT 2 i
j Regarding Safety Limit Actions, the current requirements specifying the immediate shutdown of the reactor have been deleted from Section 6.0 and relocated to TSUP section i
2.0. Previous TSUP submittals for section 2.0 allow two hours to complete the associated I
action requirement. This allows time to assess, evaluate and choose the safest course of action. The proposed changes have been shown by indusuy experience and precedence to i
provide reasonable assurance that the reactor coolant system pressure boundary integrity can l
be maintained within the requirements of the Standard Technical Specification and the Improved Standard Technical Specifications. The small time frame (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) is insignificant with respect to overall plant vulnerability, and prudently allows a reasonable time period to assess a situation in which a safety limit may be approached and thus, the proposed changes l
are appropriate.
CTS 6.5 Phnt Ooer2 ring Records l
The requirements related to Record Retention can be adequately comrolled in the UFSAR and plant procedures, revisions to which are controlled by 10 CFR 50.59. The removal of these items is consinent with changes addressed in NRC letter from W. T. Russell to Owners Group Chairmen, i
dated October 25,1993. In addition, the proposed changes are consistent with the guidance provided in the BWR Improved Standard Technical Specifications, NUREG-1433.1.
j CTS 6.6 Reoorrine Reauirements 1.
CTS 6.6.A.1 has been deleted from TSUP. These requirements can be adequately controlled l
in the UFSAR and plant procedures by 10 CFR 50.59. Eliminating repetition of these details from the Technical Specifications will not compromise plant safety. The removal of these items is consistent with changes addressed in NRC letter from W.T. Russell to Owners Group Chairmen, dated October 25,1993. In addition, the proposed changes are consistent with the guidance provided in the BWR Improved Standard Technical specifications, NUREG-1433.
I 2.
CTS 6.6.A.2 is encompassed within TSUP 6.9.A.2.a. The proposed TSUP requirements are equivalent to CTS reqwrements.
i 3.
CTS 6.6.A 3 is encompassed within TSUP 6.9.A.5 and the ODCM. The proposed TSUP requirements are equivalent to CTS requirements.
4.
CTS 6.6.A.4.a.(1),(3),(4) and (5) are encompassed within TSUP 6.9.A.6.a. CTS 6.6.A.4.a.(2) and 6.6.A.4.a.(6) are encompassed within TSUP 6.9.A.6.a.(4). The proposed TSUP requirements are equivalent to CTS requirements.
5.
CTS 6.6.A.4.b is encompassed within TSUP 6.9.A.6.b. The proposed TSUP requirements are equivalent to CTS requirements.
6.
CTS 6.6.A.4.c is encompassed within TSUP 6.9.A.6.c. The proposed TSUP requirements are equivalent to CTS requirements.
i 7.
CTS 6.6.A.4.d is encompassed within TSUP 6.9.A.6.c. The proposed TSUP requirements are equivalent to CTS requirements.
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i ATTACHMENT 2 8.
CTS 6.6.B.1 is encompassed within TSUP 6.9.A.4. The CTS requirements for a Semi-Annual report have been modified to an Annual report. This charge is consistent with the l
final rule for reducing the regulatory burden on nuclear licensees that was published in the i
Federal Register (FR) on August 31,1992. The rule change included a revision to 10 CFR 50.36a regarding the frequency for submitting radiological effluent reports. This change is administrative in nature and makes the Technical Specifications consistent with the amendment requirement of 10 CFR 50.36a. The change does not adversely impact the l
ability to meet applicable regulatory requirements related to liquid and gaseous effluents.
The proposed change will eliminate an unnecessary administrative burden without reducmg the protection of the public health and safety. Proposed TSUP 6.9.A.4 is consistent with a similar amendment previously approved for Byron and Braidwood Stations (G. Dick letter to D. Farrar, dated February 2,1995).
9.
CTS 6.6.B.2 is encompassed within TSUP 6.9.A.3 and the ODCM. The proposed TSUP requirements are equivalent to CTS requirements.
- 10.
TS 6.6.B.3 is encompassed within TSUP 6.9.A.2.b. The proposed TSUP regturements are j
consistent with the requirements in the Byron /Braidwood TS. The proposed reporting requirements for Specific Activity in the reactor coolant ensures the appropriate l
information, consistent with industry practices, is submitted to the Commission.
11.
CTS 6.6.B.4 is encompassed within TSUP 6.9.B. The proposed TSUP requirements are equivalent to CTS requirements.
12.
CTS Table 6.6-1 has not been retained in TSUP 6.0. The individual requirements for special repons are described within each individual specification. The proposed TSUP requirements are consistent with the requirements in the Byron /Braidwood TS.
CTS 6.7 Environmental Qualification CTS 6.7.A and CTS 6.7.B regarding the Environmental Qualification requirements have not been retained with TSUP 6.0. CTS 6.7, Environmental Qualification (EQ), is being deleted in j
accordance with 10CFR 50.6, Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants. 10 CFR 50.49 supersedes the current requirements in the 3
Technical Specifications.
CTS 6.8 Offsite Dose Calcuinion Manual (O])Qd) 1.
CTS 6.8.A regarding the definition of the ODCM is encompassed within TSUP 1.0, j
" Definitions," for the ODCM. The TSUP definition for ODCM has been previously
}
approved by the NRC staff (J. Stang letter to D. Farrar, dated February 16, 1995).
i CTS 6.8.A regarding the submittal of the ODCM at the time of RETS to the Commission j
is superseded by proposed TSUP 6.14.A.3. The CTS 6.8.A requirements are obsolete and based upon Quad Cities' TS submittal in the early 1980's related to the incorporation of j
the original Radiological Effluents Technical Specifications (R. Bean letter to D. Farrar, dated June 19, 1984). The proposed TSUP 6.14.A.3 requirements are consistent with the i
guidance provided in Generic Letter 89-01 and are consistent with the Byron /Braidwood l
Technical Specification requirements.
i I
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t, ATTACHMENT 2 2.
CTS 6.8.B is encompassed within TSUP 6.14.A.1 and TSUP 6.14.A.2. The proposed TSUP 6.14.A.1 and 6.14.A.2 requirements are consistent with the guidance provided in Generic Letter 89-01 and are consistent with the Byron /Braidwood Technical Specification requirements.
CTS 6.9 Proceu Cnntrol Program (PCP)
- 1.
CTS 6.9.A regarding the definition of the PCP is encompassed within TSUP 1.0,
" Definitions," for the ODCM. The TSUP definition for PCP has been previously approved
. by the NRC staff (J. Stang letter to D. Farrar, dated February 16, 1995).
2.
The CTS 6.9.B requirements are obsolete and based upon Quad Cities' TS submittal in the early 1980's related to the incorporation of the original Radiological Effluents Technical Specifications (R. Bean letter to D. Farrar, dated June 19, 1984). The proposed TSUP 6.13.A requirements are consistent with the guidance provided in Generic Letter 89-01 and are consistent with the Byron /Braidwood Technical Specification requirements.
l 4.
- CTS 6.9.C is encompassed within TSUP 6.13.A.1 and 6.13.A.2. The proposed TSUP 6.13.A.1 and 6.13.A.2 requirements are consistent with the guidance provided in Generic Letter 89-01 and are consistent with the Byron /Braidwood Technical Specification
~
requirements.
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CTS 6.10 Maior Changes to R2dwaste Treatment Systems l
i Current Specification 6.10, Major Changes to Radioactive Waste Treatment Systems, is being i
deleted in accordance with Generic Letter 89-01, " Implementation of Programmatic Controls for-Radiological Effluent Technical Specifications in the Administrative Controls Section of the Technical Specifications and Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program." The programmatic requirements contained within the current specification are relocated to the Offsite Dose Calculation Manual in i
accordance with the Generic Letter.
CTS 6.11 RaAlation Protection Program CTS 6.11.1 is encompassed within TSUP 6.11. The proposed TSUP requirements are equivalent to CTS requirements.
j CTS 6.12 High R=distion Area 1.
The proposed Section 6.12 is adopted from CTS 6.12. The proposed section is a newrite of the current requirements with modifications stated below.
The defm' ition of HIGH RADIATION AREA is revised in.10 CFR Part 20. Section 6.12, which describes administrative controls for HIGH RADIATION AREA (s), is changed to apply when dose rates are above 100 mrem /hr at 30 cm (12 in.).
. 2.
The proposal removes the requirement to establish a stay time for personnel entering HIGH RADIATION AREA (s) with dose rates above 1000 mrem /hr at 30 cm (12 in.). Instead, a requirement is added that requires persons entering a HIGH RADIATION AREA with dose rates above 1000 mrem /hr at 30 cm (12 in.) to have an alarming radiation monitoring kAnla\\ quad \\tsup\\60_att2.wpf
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e ATTACHMENT 2 device or to have surveillance and radiation monitoring by a Radiation Protection Technician. This ensures that exposure control is maintained.
i in emergency situations which involve personnel injury or actions taken to prevent major equipment damage, surveillance and radiation monitoring of the work area by a qualified
)
individual may be substituted for routine RWP procedure Miscellaneous New Reauirements 1.
Specification 6.1, " Responsibility," is a new specification that provides clarification and enhanced guidance regarding the roles and responsibilities of site leadership. The proposed requirements are consistent with the TS requirements located within the Byron /Braidwood TS.
2.
Specification 6.8.B.1 is a new specification for the program Reactor Coolant Sources Outside Primary Containment. The proposed program ensures that leakage from those portions of systems outside primary containment that contain highly radioactive liquid, remain as low as possible. The proposed specification replaces the current license condition for Systems Integrity for DPR-29 (Quad Cities Unit 1) and DPR-30 (Quad Cities Unit 2). The marked-up revised license pages are included in Attachment 4.
3.
Specification 6.8.B.2 is a new specification for the program In-Plant Radiation Monitoring.
The proposed program ensures the capability to accurately determine the airborne iodine concentrations. The proposed specification replaces the current license condition for Iodine Monitoring for DPR-29 (Quad Cities Unit 1) and DPR-30 (Quad Cities Unit 2). The marked-up revised license pages are included in Attachment 4.
l 4.
Specification 6.8.B.3 is a new specification for the program Post Accident Sampling. The proposed program ensures the capability to obtain and analyze reactor coolant, gaseous 1
effluents, and containment atmosphere samples under accident conditions for DPR-29 (Quad Cities Unit 1) and DPR-30 (Quad Cities Unit 2). The proposed specification replaces the j
current license condition for Post Accident Sampling for DPR-29 (Quad Cities Unit 1) and DPR-30 (Quad Cities Unit 2). The marked-up revised license pages are included in.
5.
Specification 6.8.B.4 is a new specification for the program Radioactive Effluent Controls Program. The program ensures that the doses to the members of the public from radioactive effluents will remain as low as reasonably achievable.
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SUMMARY
AND SCHEDULE The proposed changes to the Quad Cities Station Technical Specifications have been reviewed and approved by the Onsite Review in accordance with controlled Station Procedures. Commonwealth Edison has reviewed these proposed amendments in accordance with 10CFR 50.92(c) and determined that no significant hazards consideration exist. This evaluation is documented in Attachment 6. It is requested that the proposed amendment be approved no later than November 3,1995 and made effective upon completion of the entire Technical Specification Upgrade Program (TSUP).
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ATTACHMENT 3 i
PROPOSED TECHNICAL SPECIFICATIONS Technical Specification 6.0
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