Text

Proposed Tech Specs,Clarifying Applicability of Containment Oxygen Concentration & Drywell Torus Differential Pressure Limiting Conditions for Operation & Surveillance Requirements
	ML20154D508
Person / Time
Site:	Quad Cities
Issue date:	05/09/1988
From:	; COMMONWEALTH EDISON CO.
To:	;
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ML20154D503	List: ML20154D498; ML20154D508;
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	4410K, NUDOCS 8805190214
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d ATTACIGENT 1 PROPOSED CHANGES TO APPENDIX A ,

e TECHNICAL SPECIPICATIONS POR ,

L i 00AD CITIES STATION UNITS 1 AND 1 i l

FACILITY OPRRATING LICENSES DPR-29 AND DPR-30 i

Revised Peges: 3.7/4.1-6 (DPR 29) ;

3.7/4.7-64 (DPR 29) l 3.7/4.7-7 (DPR 29) I

, 3.7/4.7-13 (DPR 29) 3.7/4.7-6 (DPR 30) i l 3.7/4.7-64 (DPR 30)

3.7/4.7-7 (DPR 30) l

, 3.7/4.7-13 (DPR 30) t l

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4 4410K '

i 8805190214 DR ADOCK880509 05000254 oco ,.

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+. - - 00AO-h! TIE 5

.. DPR+29

. e points along tha seal 2) Vacuum breaker p;sititn surface of the disk. indication and alarm systems shall be

3) The position alarm calibrated and system will annunciate functionally tested.

in the control room if the valve opening 3) At least 25% of the exceeds the equivalent vacuum breakers shall of 1/16 inch at all be inspected such that points along the seal att vacuum breakers surface of the disk, shall have been inspected following

b. Any pressure-suppression every fourth refueling chamber-drywell vacuum outage. If breaker may te non-fully deftciencies are found, closed as indicated by the all vacuum breakers position indication and shall be inspected and alarm systems provided that deficiencies corrected, drywell to suppress *on chamber differential 4) A drywell to pressure decay rate is suppression chamber demonstrated to be not leak test shall greater than 25% of the demonstrate that with differential pressure decay initial differential rate for all vacuum breakers pressure of not less open the equiv41ent of 1/16 than 1.0 psi, the inch at all points along the differential pressure seal surface of the disk, decay rate does not exceed the rate which

c. Reactor operation may would occur through a continue provided that no 1-inch orifice without more than one quarter of the the addition of air or number of pressure nitrogen.

suppression chamber-drywell vacuum breakers are determined to be inoperable provided that they are secured or known to be in the closed position. i

d. If failure occurs in one of the two-position alarm systems for one or more vacuum breakers reactor operation may continue provided that a differential pressure decay rate test is initiated innedtately and performed every 15 days thereafter untti the failure is corrected. The test shall seet the requirenents of 50ecification 3.7.A.4.b.

5 Cnygen Concentration 5. Oxygen Concentratien

a. When the reactor is in the Tne oxygen concentration in the RUN Mode, the primary primary Containment shall be containnent atmosphsre verified to be within the limit concentration shall te less of specification 3.7.A.5.a. at than a percent oxygen least once per seven days, concentration by volume, while in the RUN Mode.

except as specified in 1) or

2) below:

1) Subsequent to placing the reactor in the EUM Mode, the containment atmosphere oxygen concentration snail be reouced to at least 4 l percent by volume within J

' 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or within the nest 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months te 'n at least the Startup/ Hot 5tanoby Hoce.'

09558 3.7/a.7-6 Amenoment No.

.. . . . QU AO-C IT!!$

DPR.29

. .i

2) ' Deinerting may commence !

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a shut down. If this 24 .

hour period is exceeded.

be in at least the }

4 Startup/ Hot Standby Mode '

within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .' ,

t 4- b. When the oxygen ;

concentration in the primary t containment exceeds the i i limit given in specification !

3.7.A.$.a. above within 24 .

-hours restore the oxygen !

concentration to within the I limit, or within the ne:L 6 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months be in at least the [

$7ARTUP/ HOT $TANOSY Mode.

6. Containment Systems 6. Containment Systems l l t orywell-Suppression Chameer nrywell-Suppression Chamter !

Differential Pressure Differential Pressure l

a. When the reactor is in the a. The pressure differential

, RUN mode, the differential between the drywell and pressure between the drywell suppression chamber shall be r and suppression chamber recorded at least once each l thall be maintained at equal shift wnen in the RUN Mode, i to or greater than 1.20 l osid. except as specified in .

r

1) or 2) celow: !

u l l 1) This differential &

pressure shall be 6 i established within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months pericd subsequent to placing r

)

the reactor mode switch l into the RUN Mode during i a startup when the ;

provisions of }

j. 3.7.A.S.a.(1) apply. If .

> this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period is exceeded, be in at least t the $tartup/ Hot Standby (

Mode within the nest 6 [

hours.

2) This differential [

pressure may br relaxed i

2. hours prior to j reactor shutcown when i the provisions of ,

j 3.7.5.4.(2) apply. tf j this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period is t exceeded, within the , I next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months be in at }

i least the Startup/ Hot Standby Mode.

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j 09558 3.7/a.7-6a Amensment No.

1

. Qua0-CITIES OPR-29

b. When the differential pressure is less than the'

, 11stt given is specification 3.7.A.6.a. above, encept as specified in 3.7. A.0.c. and 3.7. A.6.d. below, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the differentist pressure to within the limit, or within the nest 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months be in at least the STARTUP/ MOT STAe0tY Mode and in COLO

$MUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

l c. This pressure differential m.y be decreased to icii than 1.20 P$10 for a mastmum of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during reeutred operett11ty testing of the NPCI system pump, the RCIC system pump, the drywell-pressure suppression chamber vacuum breakers. and reactor pressure relief valves.

d. If the $pecifications of l 3.7.A.6.c. cannot be met.

and the differential pre,sure cannot be restored within the subsequent six (6) hour perted, an orderly shutdown shall be initiated and the reactor shall be in i a cold shutdown condition in I the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

8. Standby Gas Treatment System 8. Standby Cas treatment System

1. Two separate and indepen6ent 1. at least once per month, standb/ gas treatment system initiate f rom the control room circuits shall be operable at 4000 cfm (t 101) flow through all times when secondary con- both circuits of the standby gas tai;went integrity is reoutred. treatment system f or at least 10 except as scocified in sections hours with the circuit heaters 3.7.3.1.(a) and (b). operating at rated power.

4. After one of the standby gas 4. Within I hours from the time treatment systems circuits that one standby gas is made or found to be treatment system circuit is inoperable for any reason, maae or found to be reactor operation and fuel inoperable for any reason I handling is permissible only and daily thereafter for the l during the succeeding 7 nest succeeding 7 days.

I days, provided that all initiate from the control I active canponents in the room 4000 cfm (t 10%) flow

! other stancey gas treatment through the operable circutt system shall be demonstrated of the standby gas treatment to be c;erable within 2 system for at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months hours and daily thereafter, with the circutt heaters Within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months following operating.

the 7 days, the reactor shall te places in a condition for mMich the standby gas treatment system is not required in accordance with $pecifica-tion 3.7 C l(4) through (d),

b. If both standby gas treatment system circuits are not operable, within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months the reactor shall be placci in a condition f or which the staneby gas treatment system is not required in accordance with

$pecificat ion 3.7.C.1.(a) 09$58 3.7/4.7 7 A*enanent 40.

CUAO-CIT!!$ ,

ope-29 l hydrogen, if it is present in sufficient quantities to result in excessively rapid recastination, could result in a loss of containment integrity. [

l The at oxygen concentration by volume minimizes the possibllity of hydrogen i combustion following a less-of-coolant acct $ent. $tgnificant quantities of hydrogen could be generated if the core cooliag systers did not suf ficiently cool the core. Providing an LC0 by volume is consistent with the f act that - f the oxygen analyser indicated in % oxygen by voluse, f The occurrence of primary system leakage following a major refueling outage [

or other scheduled shutdown is much more probable than the occurrence of the .

loss-of-coolant accident upon which the spectf ted oxygen concentration limit [

is based, Permiting access to the drywell for leak inspections Ouring a :

I startbJ ts judged prudent in term 1 of the added plant safety offered without significantly resucing the surgin of safety. Thus. to preclude the !

possibility of starting the reactor and operating fcr extended periods of l time with significant leaks in the primary system. leak inspections are ,

scheduled during startup periods, when the primary system is at or near rated i operating temperature and pressure. l A 24-hour relaxation of the osygen concentration requireeent period is judged {

to be sufficient to perfonn the leak inspection and estabitsh the required !

oxygen concentration. The 24-hour time Itmit also provides a restricted time period for a containment entry to be made with the reactor at power in order to affect minor repairs to safety equipment and to perform equipment lubr ic at i on. The primary containnent is normally slightly pressurtred during periods of reactor operation. Nitrogen Vsed for inerting Could leak out of the containment but air cculd not leak in to increase cuygen Concentration.

Once the containment is filled with nitrogen to the required concentration, no monitoring of oxygen Loncentration is necessary. However at least once a week, the oxygen concentration will be determined as added assurance.

In conjunctio) with the Mark 1 Containnent Short Term Program, a plant unique analysts was performed (Reference 5) which demonstrated a factor of safety of at least two for the weakest element in the suppression chamber support system and attached piping. The maintenance of a drywell-suppression chan6er dif ferential pressure of 1.20 psid and a suppression chaneer water level correspondtng to a downcomer submergence range of 3.21 to 3.$4 feet will allure the integrity of the suppression chamoer when subjected to post-t0CA suppression pool hydrodynamic forces.

8. Standby Cas Treatment System The standby gas treatment system is designed to filter and exhaust the reactor but1 ding atscsphere to the chimney during secondary contatnment isolation conditions, with a minimum release of radioactive materials f rom the reactor building to the environs. One standby gas treatment system circuit is designed to automatically start upon contatnpent isolation and to maintain the reactor building pressure at the design negative pressure so that all leak'ge should be in-leakage. Should one circutt fail to start, the re$undant alternate standby gas treatment circuit is designed to start automatically. Each of the twc circuits has 1001 capacity. Only one of the two standby gas treatment system circutts is needed to cleanup the reactor building atmosphere upon containment isolation. If one system is found to be inoperable, there is not immediate threat to the containment system performance. Therefore, reactor operation or refueling operation may continue while repatrs are being made. If neither circuit is operable. the plant is placed in a condition that does not require a standby gas treatment system.

While only a small ascunt of particulates are released f rom the primary containment as a result of the loss-of-coolant accident, high-efficiency par-titulate filters before and after the charcoal filters are specified to min-tmtre potential particular release to the environment and to prevent clogging of the charcoal adsorbers. The 09555 3.7/a.7-13 Amendme6t ho.

I QUAD-C17!!$

DPR-30 points along th3 seal 2) Vacuum breaker position surface of the disk. indication and alarm systems shall be

3) The DGlition alarm calibrated and system will annunciate functionally tested.

in the control room if the valve openir.g 3) At least 25% of the exceeds the equivalent vacuum breakers shall of 1/16 inch at all be inspected such that points along the seal all vacuum breakers surface of the disk. shall have been inspected following

b. Any pressure-suppression every fourth refueling chamber-drywell vacuum outage. If breaker may be non-fully deficiencies are found, closed as indicated by the all vacuum breakers position indication and shall be insp2cted and alarm systems provided that deficiencies corrected.

drywell to suppression chanter dif ferential 4) A drywell to pressure deepy rate is suppression chamber demonstrated to be not leak test shall greater than 25% of the demonstrate that with differential pressure decay initial differential rate for all vacuum breakers pressure of not less open the equivalent of 1/16 than 1.0 psi, the inch at all points along the differential pressure seal surface of the disk. decay rate does not exceed the rate which C. Reactor operation may would occur through a continue provided that no 1-inch orifice without more than one quarter of the the addition of air or number of pressure nitrogen.

Suppression chamber-drywell vacuum breakers are determined to be inoperable provided that they are secured or known to be in the closed position.

d. If failure occurs in one of the two-positten alarm systems for cne or rcre vacuum breakers, reactor operation may continue provided that a differential pressure decay rate test is initiated immediately and performed every 15 days thereafter untti the failure is corrected. The test shall meet the requirenents of 5pecification 3.7.A.4.0.

5. Oxygen concentration 5. Cnygen Concentration

a. When the reactor is in the Tre cuygen concentratten in the RUN moce, the primary primary containrent shall be containrent atmosphere verified to be within the limit concentration shall te less of specification 3.7.A.5.a. at than 4 percent oxygen least ence per seven days, concentration by volume, wntle in the ELN Mcde, except as specified in 1) or

2) telcw:

1) Subsecuent to placing the reactor in the eUN Moce, the contatnment atmos;nere oxygen concentration small te reduced to at least a percent by volume within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or within the nest 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months te in at least the Startup/ Hot Standby Moce.

c9558 3.7/a.7-6 Amen omen t No.

N

DPR-30

2) Deinerting may commence

. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a shutdown. If this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months peri!d is etcC0ded, be in at least the Startup/ Hot standby Mode within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

b. When the oxygen concentratio.i in the primary containnent exceeds the limit given in specification 6. Containment Systems 3.7.A.$.a. above, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restore the oxygen Drywell-$uppression Chamber concentration to within the Otfferential Presture 11m't. or within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months be in at least the a. The piessure differential STARTUP/ HOT STANDBY Mode. between the drywell and suppression chameer shall be

6. Conidinment Systems recorded at least once each shift when in the RUN Mode.

Drywell-tuporession Chamber Differential Pressure

a. When the reactor is in the RUN mode, the differential pressure between the drywell and suppression chamber shall be maintained at equal to or greater than 1.20 psid.except as specified in

1) or 2) below:

1) This differential pressure shall be established within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period subseouent to placing the reactor mode switch into the RUN Mode during a startup when the provisions of 3.7. A.5.a.(1) apply. If this 24 hcur period is exceeded. be in at least the Startup/ Hot Standby Mode within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2) This differential pressure may be relaxed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reactor shutdown when the provisions of 3.7.5.a.(2) apply. If this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period is esteeded, within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months te in at least the Startup/ Hot Stancey Mode,

b. When the differential pressure is less than the limit giv(n in s;ecificalich 3.7.A.6.4. above, except as specified in 3.7 A 6.c. and 3.7,A.6.d. below, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months restora the differential pressure to wt'hiri the limit. or within the next 4 hcurs te in at least the $TARTUP/ MOT

!TANOBY M0de and in CCLD

$HUTCCbH within the follcairg 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

C9555 3.7/4.7-ta Ate n ace n t N o .

-I QUAD-CITIES

' D?R-30

c. This pressure differential may be decreased to less than 1.20 PSID for a maximum of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during required operability testing of the HPCI system pump, the RCIC system pump, the drywell-pressure suppression chamber vacuum breakers, and '

reactor pressure relief valves.

d. If the Specificattuns of 3.7.A.6.c. cannot be met, and the dif ferential B. Standby Gas Treatment System pressure cannot be restored within the subsequent six 1. At least once per month.

(6) hour period, an orderly initiate from the control room shutdown shall be initiated 4000 cfm (i 10%) flow through and the reactor shall be in both circuits of the standby gas a cold shutdown condition in treatment system for at least 10 the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . hours with the circuit heaters operating at rated power.

a. Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months from the time that one standby gas B. Standby Gas Treatment System treatment system circuit is made or found to be

1. Two separate *.nd independent inoperable for any reason standby gas treatment system and daily thereafter for the circuits shall be operable at next succeeding 7 days, all times when secondary con- initiate from the control tainnent integrity is required, room 4000 cfm (i 10%) flow except as specified in sections throu2h the operable circuit 3.7.B.1.(a) and (b). of the standby gas treatment system for at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months

a. After one of the standby gas with the circuit heaters treatment systems circuits operating.

is made or found to be .

inoperable for any reason, reactor operation and fuel handling is permissible only during the succeeding 7 days, provided that all active components in the other standby gas treatment system shall be demonstrated to be operable within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and daily thereafter.

Within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months following the 7 days, the reactor s5a11 be placed in a condition for which the standby gas treatment system is not required in accordance with Specifica-tion 3.7.C.1(a) through (d).

b. If both standby gas treatment system circuits are not operable, within 36 i hours the reactor shall be placed in a condition for which the standby gas treatment system is not required in accordance with Specification 3.7.C.I.(a) through (d).

09558 3.7/4.7-7 Amendrent No.

t QUAD-CITIES DPR-30 hydrogen, if it is present in sufficient quantities to result in excessively rapid recombination, could result in a loss of containment integrity.

The 4% oxygen concentration by volume minimizes the possibility of hydrogen canbustion following a loss-of-coolant accident. Significant quantities of hydrogen could be generated if the core cooling systems did not sufficiently cool the core. Providing an LCO by volunt is consistent with the f act that the oxygen analyzer indictted in % oxygen by volume.

The occurrence of primary system leakage following a major refueling outage or other scheduled shutdown is much more probable than the occurrence of the loss-of-coolant accident upon which the specified oxygeit concentration limit is based. Permiting access to the drywell for leak inspections during a '

startup is judged prudent in terms of the added plant safety offered without significantly reducing the margin of safety. Thus, to preclude the possibility of starting the reactor and operating for extended periods of time with significant leaks in the primary system, leak inspections are schedule 1 during startup periods, when the primary system is at or near rated operating temperature and pressure.

A 24-hour relaxation of the oxygen concentration requirement period is judged to be sufficient to perform the leak inspection and establish the required oxygen concentration. The 24-hour tine limit also provides a restricted time period for a containnent entry to be made with the reactor at power in order to affect minor repairs to safety equipment and to perform equipment lubrication. The primary containment is normally slightly pressurized during periods of reactor operation. Nitrogen used for inerting could leak out of the containment but air could not leak in to increase oxygen concentration.

Once the containnent is filled with nitrogen to the required concentration, no monitoring of oxygen concentration is necessary. However at least once a week, the oxygen concentration will be determined as added assurance.

In conjunction with the Mark I Containmer.t Short Term Program, a plant unique analysis was performed (Reference 5) which demonstrated a factor of safety of at least two for the weakest elenent in the suppression chainber support system and attached piping. The maintenance of a drywell-suppression chamber differential pressure of 1.20 psid and a suppression chamber water level corresponding to a downcocer submergence range of 3,21 to 3.54 feet will assure the integrity of the suppression chamber when subjected to post-LOCA suppression pool hydrodynamic forces.

B. Standby Gas Treatment System The standoy gas treatment system is designed to filter and exhaust the reactor building atmosphere to the chimney during secondary containment isolation conditions, with a minimum release of radioactive materials from the reactor building to the environs. One standby gss treatment system circuit is designed to automatically start upon containnent isolation and to maintain the reactor building pressure at the design negative pressure so that all leakage should be in-leakage. Should one circuit fail to start, the redundant alternate standby gas treatment circuit is designed to start automatically. Eacn of the two circuits has 100% capacity. Only one of the two standby gas treatment system circuits is needed to cleanup the reactor building atmosphere upon containment isolation. If one system is found to be inoperable, there is not immediate threat to the containment systtu performance. Therefore, reactor operation or refueling operation may continue while repairs are being made. If neither circuit is operable, the i plant is placed in a condition that does not require a standby gas treatment I system.

While only a small amount of particulates are released from the primary l containment as a result of the loss-of-coolant accident, high-effi:iency par-l ticulate filters before and after the charcoal filters are speciritd to min-l imize potential particular release to the environmerit and to prevei t clogging of the charcoal adsorbers. The l

l l

09558 3.7/4.7-13 Amendment No.

L

ATTACHMENT 2

SUMMARY

OF CHANGES L

i A total of thirty (30) changes to the Quad cities Station Units 1 and l 2 Technical Specifications have been identified (15 per unit) and are listed (

below as follows:

1) Page 3.7/4.7-6, DPR-29 and 30 ,

1 (a) Limiting condition for Operation (LCO), Technical Specification 3.7.A.5.a - Delete Item (a) and replace with following statement, "When the reactor is in the RUN Mode, the primary containment atmoaphere concentration shall be less than 4 percent oxygen concentration by volume, except as specified in 1) and 2) below,"

(b) LCO Technical Specification 3.7.A.5.a - Under new Specification 3.7.A.S.a (as identified in above Item 1 (a)), insert new Specification 3.7.A.5.a.1) which reads as follows, "Subsequent to placing the reactor in the RUN Mode, the containment ... in at least the Startup/ Hot Standby Mode."

(c) Surveillance Requirements Technical Specification 4.7.A.5 - Delete Item 5, entitled "Oxygen Concentration" and replace with following statement, "The oxygen concentration in the primary containment shall be verified to be within the limit of specification 3.7.A 5.a at least once per seven days, while In the RUN Mode."

l

2) Page 3.7/4.7-6a, DPR-29 and 30 (a) LCO - Technical Specification 3.7.A.5.a - Insert new Specification l

3.7.A.5.a.2 under 3.7.A.5.a.1 which reads as follows, "Deinerting l may commence 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a shutdown ... within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ."

(b) LCO - Technical Specification 3.7.A.5.b - Delete Item (b) and replace with following statement, "When the oxygen concentration in the primary containment exceeds the limit given in ... be in at least the STARTUP/ HOT STANDBY Mode."

(c) LCO - Technical Specification 3.7.A.6.a - Delete Item (a) and replace with following statement, "When the reactor is in the RUN Mode, the differential pressure ... or greater than 1.20 psid, except as specified in 1) or 2) below."

(d) LCO - Technical Specification 3.7.A.6.a - Under Specification 3.7.n.6.a, insert Item 3.7.A.6.a.1, which reads as follows, "This differential pressure shall be established ... be in at least the Startup/ Hot Standby Mode within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

(e) LCO - Technical Specification 3.7 A.6.a - Under new Specification 3.7.A.6.a.1 (as identified in above Item 2(d)) insert new Specification 3.7.A.6.a.2, which reads as follows, "This differential pressure may be relaxed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ... be in at least the Startup/ Hot Standby Mode."

(f) Surveillance Requirements 4.7.A.6.a - Delete phrase "When the differential pressure is required.", and replace with phrase "When in the RUN Mode.", so the Surveillance Requirement now reads, "The pressure differential between ... when in the RUN Mode."

3) Page 3.7/4.7-7, DPR-29 and 30 (a) Insert new item, Technical Specification 3.7.A.6.b, which reads as follows: "When the differential pressure is less than the limit given in Specification 3.7.A.6.a above ... in at least the STARTUP/ HOT STANDBY Mode and in the COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ."

(b) Relabel Technical Specification Item 3.7.A.6.a.(2), to be Item 3.7.A.6.c.

(c) In existing Technical Specification 3.7.A.6.a.(2) (now relabeled to be 3.7.A.S.c) insert the word pressure preceeding the word differential so the statement now reads "This pressure differential may be ... "

(d) Relabel Technical Specification Item 3.7.A.6.b, to be Item 3.7.A.6.d.

(e) In existing Technical Specification 3.7.A.6.b (now relabeled to be 3.7.A.7.d), change "3.7.A" to "3.7.A.6.c" to reflect the above referenced changes to the Containment Systems Drywell -

Suppression Chamber Diffarential pressure Technical Specifications, so the sentence now reads, "If the specifications of 3.7.A.6.c cannot be met ... "

4) page 3.7/4.7-13, DPR-29 and 30 (a) Third paragraph, first line - Delete "The 24-hour period to provide inert 3ng" and replace with "A 24-hour relaxation of the oxygen concentration requirement period", so the sentences now read "A 24-hour relaxation ... and to perform equipment lubrication."

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ATTACHMENT 3 DESCRIPTION OF PROPOSED AMENDMENT REOUEST An item by item description of the proposed changes requested as part of this amendment is provided for information and use. Attachment 2 can be referred to in order to reference back to a given change and its affected page.

Overall, the changes that are described in this proposed amendment are a result of providing a clear action statement should the oxygen concen-tration or torus drywell differential pressure LCO's be exceeded. The action statement would provide 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to either restore the LCO or be in STARTUP/ HOT STANDBY in the subsequent 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN in the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

There are several administrative changes associated with this amendment where the affected oxygen concentration or torus drywell differential pressure Technical Specifications have been renumbered as a result of this change.

Finally, several changes have been made to the Technical Specification and/or Bases for clarification. These changes, as well as the numbering changes, are considered to be administrative in nature.

Items 1(a)

The proposed change rewords the applicability of the LCO to the RUN Mode.

Items 1(b)

The proposed change establishes an action statement for time clock references subsequent to going into RUN mode. Action statement requires that if this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period is exceeded, within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months be in at least the STARTUP/ HOT STANDBY MODE.

Item 1(c)

This proposed change clarifies the applicability of the oxygen concentration surveillance to the time period when the LCO is applicable, i.e., when in the RUN Mode.

Item 2(a)

This section maintains the provision of the original Technical Specification allowing deinerting to be initiated 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a reactor shutdown. It also provides an action statement should the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period be exceeded, within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months be in at least the STARTUP/ HOT STANDBY Mode.

Item 2(b)

The proposed change establishes a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time clock to restore the LCO or be in at least STARTUP/ HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Item 2(c)

The proposed change rewords the applicability of the LCO to the RUN Mode.

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Item 2(d)

The proposed change establishes an action statement for time clock references subsequent to going into the RUN Mode. Action statement requires that it the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period is exceeded, within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months be in in at least the STARTUP/ HOT STANDBY Mode.

Item 2(e)

This ection maintains the provisions of the original Technical Specification allowing the torus /drywell differential pressure to be relaxed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a reactor shutdown. It also provides an action statement should the 24 prior be exceeded, within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months be in at least the STARTUP/ HOT STANDBY Mode.

Item 2(f)

This proposed change clarifies the applicability of the surveillance requirement to when in the RUN Mode in lieu of when differential pressure is required.

Item 3(a)

This proposed change creates a new paragraph in Technical Specification 3.7.A.6.b, which establishes a 24-hour time clock to restore the LCO or be in at least STARTUP/ HOT STANDBY in the subsequent 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and cold shutdown in the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Item 3(b) & 3(c)

This proposed change is a renumbering of existing Specification 3.7.A.6.a(2) to 3.7.A.6.c because of the addition of the Technical Specification as described in Items 3(a). Additionally, the word "pressure" has been added to the existing specification for clarity.

These changes are considered to be administrative in nature.

Item 3(d) & 3(e)

This proposed change renumbers existing Specification 3.7.A.6.a(3) to 3.7.A.d because of the addition of the Technical Specification as described in Item 3(a). Additionally, it incorporates the change described in Item 3(b) in the body of the specification. This is considered to be administrative in nature.

Item 4(a)

This change to the bases is provided for clarification and is considered to be administrative. It describes the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period during which ,

examinations may be done with a deinerted containment as relaxation from the oxygen concentration LCO. The change to the bases allows for the possibility of making minor repairs during reactor power operation.

l ATTACHMENT 4 BASIS FOR SIGNIFICANT HAZARDS CONS;DERATION As stated in Attachment 3, Description of proposed Amendment Request, there are three types of changes associated with this Technical Specification amendment. First, there are the changes which result from providing an Action Statement for oxygen concentration and torus drywell differential pressure, should the LOO's be exceeded. Secondly, there are administrative changes which result from the addition of the action statement which in some cases, required the renumbering / reformatting of existing Technical Specifications. Lastly, there are changes that have been made to the Technical Specifications and/or bases for clarification purposes. These too, are considered to be administra-tive in nature.

These changes have been reviewed by Commonwealth Edison and we believe that they do not present a Cignificant Hazards Consideration. The basis for our determination is documented as follows:

BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION Commonwealth Edison has evaluated this proposed amendment and determined that it involves no significant hazards consideration. In accordance with the criteria of 10 CPR 50.92(c), a proposed amendment to an operating license involves no significant hazards considerations 12 operation of the facility, in accordance with the proposed amendment, would not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated because:

(a) power operation is presently permitted with containment oxygen concentration greater than 4% for only 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsequent to going to RUN and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a reactor shutdown. The change permits 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of power operation with the primary containment deinerted unrelated to reactor startup or shutdown to allow personnel to enter the drywell at power. Drywell entries are made to identify any water leakage, affect minor repairs and enable equipment lubrication.

Drywell entries other than during startup are rare. The change in time that the drywell will not be inerted during power operation allowed by this proposed change is small. Additionally, there are currently several other Mark I BWR's that are licensed for operation with a deinerted containment for periods greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

power operation is presently permitted with drywell to torus differ-ential pressure less than 1.2 psid for only 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsequent to going to RUN and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to a reactor shutdown. The change permits 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or power operation without 1.2 psid differential pressure unrelated to reactor startup or shutdown to allow personnel to enter the drywell at power. There is no change in consequences of L

3 relaxing the 1.2 psid differential pressure because the torus was analyzed for 0.0 psid as part of the Quad Cities Nculear Power Station Units 1 and 2 Plant Unique Analysis Report (Volume 2, "Suppression Chamber Analysis", Revision 0, May 1983) and was found to meet acceptance criteria.

Therefore, these changes do not significantly increata the probability increase the probability or consequences of previously evaluated accidents.

(b) The other changes to the Technical Specifications which include the renumbering of other inter-related portions of the Technical Specifications (which were affected by the proposed change) or are changes that are being sought for clarification purposes. These changes are considered to be administrative in nature.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated because:

(a) The effects of short-term deinerting have been analyzed in the PSAR.

Additionally, the torus was analyzed for 0.0 psid drywell to torus differential pressure as part of the Mark I containment Short Term program and was found to meet acceptance criteria.

Consequently, the possibility of creating a new or different kind of accident from any accident previously evaluated is unchanged.

(b) The other types of changes noted in the proposed amendment are administrative in nature.

3) Involve a significant reduction in the margin of safety because:

(a) PSAR analyses have shown that for design basis accidents, the long term combustible gas control system (ACAD/ CAM) can prevent a combustible gas mixture of 4% hydrogen even with a deinerted containment. Therefore, peak containment pressure is bounded by the PSAR LOCA analysis. The margin of safety for the torus drywell ,

differential pressure is not degraded as a result of this change because analysis of the 0.0 psid drywell to torus differential pressure concludes that acceptance criteria are met. Therefore, the pressure suppression is maintained. Hence, the changes do not reduce the margin of safety.

(b) These changes are administrative and therefore do not impact the '

margin of. safety.

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Therefore, since the proposed license amendment satisfies the criteria specified in 10 CPR 50.92, commonwealth Edison has determined.that a no signi-ficant hazards consideration exist for these items. We further request their approval in accordance with the provisions of 10 CFR 50.91(a)(4).

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SUMMARY

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