ML20205F479
| ML20205F479 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 03/31/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20205F477 | List: |
| References | |
| NUDOCS 9904060274 | |
| Download: ML20205F479 (4) | |
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UNITED STATES g
j NUCLEAR REGULATORY COMMISSION l
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WASHINGTON, D.C. J0066-0001 g
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.187 TO FACILITY OPERATING LICENSE NO. DPR-29 AND AMENDMENT NO.184 TO FACILITY OPERATING LICENSE NO. DPR-30 I
COMMONWEALTH EDISON COMPANY 6M2 MIDAMERICAN ENERGY COMPANY OUAD CITIES NUCLEAR POWER STATION. UNITS 1 AND 2 DOCKET NOS. 50-254 AND 50-265 1.0 LNTRODUCTION By letter dated January 21,1999, the Commonwealth Edison Company (Comed or the licensee) proposed changes to the Quad Cities Nuclear Power Station, Units 1 and 2, Technical Specifications (TSs). The requested changes will relocate TS 3/4.6.1, " Primary System Boundary-Chemistry" from the TSs to t:1e Updated Final Safety Analysis Report (UFSAR) and to applicable plant procedures controlled by the 10 CFR 50.59 process.
The licensee has made this request to support activities associated with an injection of noble metal compounds into the Unit 1 reactor vessel during a planned early April 1999, mid-cycle outage. The licensee states that this injection will help prevent crack initiation and to mitigate any existing crack growth due to Intergranular Stress Corrosion Cracking (IGSCC) on intems components and piping. This noble metal injection, which has been previously approved by the NRC at other facilities, will be performed in MODE 3 and will temporarily cause reactor coolant conductivity and pH levels to increase. The reactor cleanup system will reduce the conductivity and pH levels to normal levels following the injection. This amendment change could prevent l
an unnecessary cycling of the plant.
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2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to state the TSs to be included as part of the license. The Commission's regulatory requirements related to the centent of the TSs are set forth in 10 CFR 50.36. That regulation requires the TSs include items in five specific categories, including (1) safety limits, limiting safety system settings r v; e
niting control settinr 9) limiting conditions for operation; I
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2 (3) surveillan::e requiremants: (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TSs.
The four criteria defined in 10 CFR 50.So to be used in determining whether a particular matter is required to be included in the TSs, are as follows:
(1) installed instrumentation that is used to detect, and indicate in the control room a i
significant abnormal degradation of the reactor coolant pressum boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a decian basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product j
barrier; and (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.
As a result, existing TS requirements which fall within or satisfy any of the criteria in the Final Policy Statement must be retained in the TSs, while those TS requirements tiist do not fall within or satisfy these criteria may be relocated to other licensee controlled documents.
- 3. O EVALUATION The licensee has proposed relocating TS 3/4.6.1, " Primary System Boundary-Chemistry," to the UFSAR and to applicable plant procedures. This TS contains requirements for reactor coolant conductivity, chloride concentration, and pH. The amend.nent will relocate the conductivity, l
chloride, and pH requirements and associated bases to the UFSAR and applicable plant procedures.
The reactor coolant chemistry limits as specified in TS 3/4.6.1 are not used to detect and indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary as stated in criteria (1) of 10 CFR 50.36. The enductivity, chloride, and pH portion of the reactor coolant chemistry TS provides limits on particular chemical properties of the primary coolant, and surveillance practices to monitor those properties, to ensure that degiadation of the reactor coolant pressure boundary is not exacerbated by poor chemistry conditions. However, degradation of the reactor coolant pressure boundary is a long-term process, and there are other, direct means to monitor and correct the degradation of the reactor coolant pressure boundary which are controlled by regulations and TSs; for example, in-service inspection and primary coolant leakage limits. Therefore, requirements related to the chemistry program do not constitute initial conditions that are assumed in any design basis accident or transient related to the Reactor Coolant System (RCS) integrity as stated in criteria (2). Nor does the reactor coolant chemistry TS for conductivity, chloride concentration, and pH
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. constitute a primary success path and which functions or actuates to mitigate a design basis accident or transient as stated in criteria (3). Also these limits do not constitute a risk-sigr.ificant safety function warranting TS requirements under the criteria (4) of 10 CFR 50.36.
The licensee states that the reactor coolant chemistry requirements for conductivity, chloride concentration, and pH will be maintained in the UFSAR and applicable'piant procedures. Any changes to these chemistry requirements would be evaluated in accordance with 10 CFR 50.59 and if any changes are determined to involve an unreviewed safety question, the licensee must obtain prior NRC review and approval.
The relocation of the Primary System Boundary-Chemistry section from the TS to the UFSAR, and plant procedures will continue to provide adequate assurance that concentrations in excess of the limits will be detected. This is alsw consistent with NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4."
In conclusion, the above relocated requirements relating to the Primary System Boundary-Chemistry section are not required to be in the TS under 10 CFR 50.36 or $182a of the Atomic Energy Act, and are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public heath and safety. Further, they do not fall within any of the four criteria set forth in 10 CFR 50.36. In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.59 to assure continued protection of the public health and safety.
Accordingly, the staff has concluded that these requirements may be relocated from the TS to the licensee's UFSAR and applicable plant procedures.
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4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendments. The State oUicial had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such findir:g (64 FR 9186). Accordingly, the amendments meet the i
eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuanc6 of the amendments.
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6.0 CONCLUSION
i The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: R. Pulsifer Date: March 31, 1999 l
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