Text

Application for Amends to Licenses DPR-39 & DPR-48,coverting Proposed Improved Ts,Per NUREG-1431
	ML20211A912
Person / Time
Site:	Zion File:ZionSolutions icon.png
Issue date:	09/19/1997
From:	Brons J; COMMONWEALTH EDISON CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20211A919	List: ML20211A912; ML20211B994;
References
	RTR-NUREG-1431 GL-96-01, GL-96-1, NUDOCS 9709250013
	Download: ML20211A912 (90)
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ulwnu>m Septerher 19,1997 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk

SUBJECT:

Zion Station Units 1 and 2 Application for Amendment to Facility Operating Licenses DPR 39 and DPR-48 Proposed Improved Technical Specifications NRC Docket Nos. 50-295 and 50-304

Reference:

Letter, C. Shiraki (USNRC) to 1. Johnson (Commonwealth Edison), dated June 26,1997, transmitting Draft Safety Evaluation Report (SER) for Zion Station's cemversion to the improved Technical Specifications (ITS)

In the above referenced letter, the NRC provided a draft Safety Evaluation for Commonwealth Edison review, which addresses Zion Statior.'s conversion to the Improved Technical Specifications (submittals dated November 3,1995, and supplements thereto), in addition to enhancements to the Combustion Engineering steam generator tube sleeving process (submittal dated September 20,1996). The referenced letter specifically requested the following actions of Commonwealth Edison:

1

1) Verification of the accuracy of the draft SER; I

2) Preparation of a certified copy of the Technical Specifications;

3) Confirmation that the Current Tzrhnical Specifications are cons' stent with the most recent approved amendments to the current license and he scope of changes to the Current Technical Specifications are appropriate;

4) Confirm agreement with new License Condition 2.C.(12) and Appendix D regarding relocation of Technical Specification and License requirements to Licensee control;

5) Confirmation that the implementation date contained in the draft License is acceptable; 3 y ,; j 9709250013 970919 PDR ADOCK 05000295 P PDR llrlllllil lll lll l q y,e, o.. n

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6) Transmittal of Discussion of Changes which had been enhanced through discussions with the NRC;

7) Confirmation of the review and compliance with or disposition of ITS implementation issues from both San Onofre FM Peach Bottom; and, s <

8) Resubmittal of several current Technical SpHfication nark up pages I

which were not completely copied.

l l ne actions requested by the staff veill be addressed as follows.- !

1) Verificatlan of the accuraev of the draft SER

!- Attachments 1,2 and 3 provide the results of the review of the draft SER, along with recommended changes to resolve these issues. De purpose of this review is to ensure the SER reflects the Current Technical Specifications to ITS conversion, i as well as the review of differences between Zion ITS and the generic Standard i Technical Specifications, NUREG 1431. Attachment 1 are comments concerning

. the Dir,cussion of Changes, Attachment 2 are comments concerning the Discassion i of Differences from NUREG 1431, and Attachment 3 are comments concerning the CTS references and locations.

Preparation of a certified conv of the Technical SpecificatigDS 2)

Zion Station is in the process of performing a review required by Generic Letter

%01, " Testing of Safety Related Logic Circuits." Based upon the Generic 12tter

%01 review, a change to the Reactor Protection System Surveillance

, Requirements is required. In addition, as a result of huplementation reviews, additional changes to the Zion FI3 have been identified. Zion Station is l performing an additional review prior to hsuuce of the frS to provide assurance

that the technical specifications can be implemented. Therefore, preparation and

~ transmittal of a certified copy of the final Technical Specifications, including BASES changes and associated Discussion of Changes (DOC) changes es applicabic, will be completed after completion of this review.

3) Confirmation that channes to the existinn Technical Specifications are consistent with the most recent amendment to the license. and the scope of channes to the Current Technical Soecifications are anoropriate Zion Station Current Technical Specifications (CIS) were reviewed and updated to ensure that changes conform to the most recent amendment to the Zion

license. Updates to the Zion submittal, including changes to the CTS mark up, were transmitted to the NRC on June 6,1997. There have been no CTS amendments after this review was performed.

s i y aur 7 , 9-_

4 Verification of the scope of changes to the C13 will be completed with item #2, and any changes to the Cl3 mark up and applicable DOC changes will be l

provided separately.

4) Confirm anteement with new License condition 2.C112) and Anpendir D renardinn reltwation of Technical Specification and License reouirements to Ucename control Ucense Condition 2.C.(12) refers to Appendix D of the Ucense relative to relocated materials specifically requiring these materials to be relocated to the documents specified in Zion Station's conversion to the improved Technic:d Specifications dated November 3,1995, and supplements thereto. As f, art of the review of the SER, the location of relocased information was verified. The

- comments made in Attachment 3 reflect the most current informatior. for relocated information. The proposed Ucense Condition and Appndix have been found to be acceptable.

Furthermore, Commonwealth Edison confirms that material relocated to Ucensee control using the four r,creening criteria contained in 10 CFR 50.36 will be controlled under the requirements of 10 CFR 50.59 ,

5) Confirmation that the Imniementation date contained in the,. draft License is acceptable implementation of the ITS, as stated in proposed Ucense Condition 3, will be completed for both Unit 1 and 2 prior to Unit 2 entering Mode 4. This is acceptable to Zion Station.

6) Transmittal of Discuacion of Channes which had been enhanced throuah !

discu== tons with the NRC j

i Attachment 4 provides the revised Discussion of Changes, revised Discussion of '

Differences to NUREG 1431, and revised Application of Selection Criteria to the Zion Technical Specifications Report based upon review of the NRC SER and discussion with NRC staff. Additional changes to Discussion of Changes (DOC), ,

Discussion of Differences (DOD), or other submittal information identified as a result of current Zion Station review will be provided separately.

7) Confirmation of the review and comollance with or disposition of ITS i imnlementation issues from toth San Onofre and Peach Bottom Attachment 5 provides a discussion of the review of the ITS implementation issues from both San Onofre and Peach Bottom. These issues have been reviewed and they have been addressed or found to be not applicable as discussed in Attachment 5.

8) Reauhmittal of several current Technical Soccification mark un panes which were not comnletely copied

- A complete copy of the marked up Zion Current Technical Specifications will be provided following completion of the current Zion Station review. provides revisions to the generic NUREG 1431 mark up and associated Discussion of Differences.

Commonwealth Edison is notifying the State of Illinois of this appileation for amendment by transmitting a copy of this letter and its attachments to the designated state official.

To the tut of my knowledge and belief, the statements contained in this submittal are true and correct. In some instances these statements are not based on my personal knowledge, but on information furnished by other Commonwealth Edison employees, contract employees, and consultants. Such information has been reviewed in accordance with company practices and I believe it to be reliable.

Please direct any questions you may have concerning this submittal to this office.

Respectfully, e

ohn C. Brons Site Vice President Zion Station Subscribed and Sworn to before me, a Notary Pubile in and for the State of d/ hied / ,. and County of ,vfh4L; this #1/L day of v7, Ub u L@41997.-

g- 7 Q gw Q +

) ]THERESAl.SL4Y '0F ary Public, State ofIllinois Notary Public JyCommjgonExpires 7/13/99

Attachments .

Attachment 1, DOC Technical Review Attachment 2, DOD Technical Review Attachment 3, DOC lienders Attachment 4, Revised DOCS, DODs, and Application of Selection Criteria Report Attachment 5, Review of ITS Implementation issues l

Attachment 6, NUREG 1431 Mark Up and Revised DODs ;

cc: Zion Site Vice President SRB !

Regional Administrator . RIII Zion Project Manager - NRR Senior Resident inspector . Zion Station Office of Nuclear Facility Safety . IDNS IDNS Resident Inspector Master Files Reg. Assurance File DCD IJcensing

(

7.RA 97029 I:\ data \rientsip\nrceer2\rede=2\trasitti

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Attachment ZRA97029 List of Comm[tments Identified in ZRA 97029 The following table identifies those actions committed to by Comed in this document. Any other actions discussed in this submittal represent intended or planned actions by Comed. They are described to the NRC for the NRC's information and are not regulatory commitments, Please notify Mr. Robert Godley, Zion Station Regulatory Assurance Manager, or any questions regarding this document or any associated regulatory commitments.

Commitments Committed Date or Outage Zion Station concurs with the proposed License Unit 2 startup, prior Condition that commits Zion Station to implement to entering MODE 4 ITS for both Unit I and Unit 2 prior to Unit 2 entering MODE 4.

Attachment 1 DOC Technical Review NRC SER DOC 1.2 LOGICAL CONNEQQM A. 1. The Zion DOC is not discussed in the NRC SER.

Zion DOC A. 1. Propnsed Section 1.2 deals with providing specific examples of the logical connectors AND and OR and the numbering sequence associated with their use in the proposed Zion Technical Specifications. This revision is being proposed consistent with NUREG-1431.

Discrepancy Section 1.2 is included in TS, and the Zion DOC should be discussed in the NRC SER.

NRC SER DOC 1.3 COMPLETION TIMES A. 1. The Zion DOC is not discussed in the NRC SER.

Zion DOC A. 1. Proposed Section 1.3 discusses the proper use and application of Completion Times. The proposed section gives specific examples that will aid the user in understanding Completion Times in the Improved Technical Specifications. The revision is being proposed consistent with NUREG-1431.

Discrepancy Section 1.3 is included in TS, and the Zion DOC should be discussed in the NRC SER.

NRC SER DOC 1.4 FRE00ENCY A. 1. The Zion DOC is not discussed in the NRC SER.

Zion DOC A. 1. Proposed Section 1.4 discusses the proper use and interpretation of the Surveillance Frequency. The proposed section gives specific examples that will aid the user in understanding Surveillance Frequency. The proposed Frequency is consistent with current Zion I:\da ta\riont sip \nte ser 2 \r eview 2\ attach,1 1

Attachment 1 DOC Technical Review practices and NUREG-1431.

Discrepancy Section 1.4 is included in TS, and the Zion DOC should be discussed in the NRC SER. Also, the wording of the last sentence of the Zion DOC has been revised to be consistent with the wording of other DOCS for added information that was not previously addressed in the CTS. This change is contained in Attachment 4.

NRC SER DOC 2.0 SAFETY LIMITS 2.0 SAFETY LIMITS CTS 1.1.1 and fig. 1.1-lb A. 2. This figure, and the references to it, have been deleted. The figure is not applicable since Unit 2 has started up from refueling outage Z2R12.

CTS 1.1, 1.1.1, Flg. 1.1-1A A. 3. The phrases "and coolant flow" and "for four-loop operation" have been deleted since they are not needed. Zion is not licensed to operate in configurations other than four loop operation. Four loop operation is required by proposed LC0 3.4.4. Therefore, reduced coolant flow is not allowed and is not a consideration for the reactor core safety limits.

CTS Fig. 1.1-la, Footnote

A. 4. This footnote has been deleted. The figure is now applicable to both units 1 and 2 since unit 2 has started up from refueling outage Z2R12.

CTS 6.4 L A. 3. In fue event a Safety Limit is exceeded, the actions not to resume reactor operation until authorized by the NRC, to prepare a separate report for each occurrence, and to report the shutdown to the Site Vice President or his designated alternate have been deleted. The requirements regarding plant shutdown, reports, and resumption of plant operation are duplicative of regulations (10 CFR 50.36 and 10 CFR 50 Appendix E), and are inappropriate for inclusion in TS. The requirement to report the plant shutdown to the Site Vice President has no safety significance and can be controlled by the licensee outside of TS.

i I:\ data \riont sip \nt e ser 2\r eview 2 \ attach,,1 2

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Attachment 1 DOC Technical Review Zion DOC 2.0 SAFETY LIMITS 2.1 SAFETY LIMITS ISLs)

CTS 1.1.1 and Figure 1.1-lb A. 2. This figure, and the references to'it, have been deleted. The figure is not applicable since Unit 2 has started up from refueling outage Z2R12.

CTS 1.1.1 and Figure 1.1-la A. 3. The phrases "and coolant flow" and "for four-loop operation" have been deleted since they are not needed. Zion is not itcensed to-operate in configurations other-than four loop operation. Four loop operation-is. required by proposed LCO 3.4.4. Therefore, reduced coolant flow is not allowed and is not a consideration for the reactor core safety limits.

CTS Figure 1.1-la Footnote

A. 4. This footnote has been deleted. The figure is now applicable to both units 1 and 2 since unit 2 has started up from refueling outage Z2R12, 2.2 SAFETY LIMIT VIOLATIONS-CTS 6.4 L A. 3. In the event a Safety Limit is exceeded, the actions not to resume reactor operation until authorized by the NRC,-to prepare a separate report for each occurrence, and to report the s.hutdown to the Site Vice President or his designated alternate have been deleted. These same requirements are duplicative or contained in i other regulations or required to comply with regulations (10CFR50.36). This change addresses several NRC and Industry initiatives to improve the content and presentation of Administrative Controls. This change has been found to be acceptable by the NRC and Industry as documented in TSTF 5.

Discrenancy The section heading 2.1 SAFETY LIMITS does not appear in the NRC SER and should be added immediately following section heading 2.0 SAFETY LIMITS in order to preserve the proper DOC numbering order.-

The section heading 2.2 SAFETY LIMIT VIOLATIONS does not appear in the NRC SER and should be added between the first occurrence of discussion #4 and the I:\deta\aiontsip\nrcser2\ review 2\ attach _1 3

i t

! Attachment 1 DOC Technical Review second occurrence of discussion #3 under the 2.0 SAFETY LIMITS heading to preserve the proper DOC numbering order.

NRC SER DOC 2.0 SAFETY LIMIT CTS 6.4 A. 4. Current Specifications 6.1.7.A.1 and 6.1.7.B.1 require the Safety Limit violation to be reviewed by both the offsite and onsite review and investigative functions, respectively. These CTS requirements are moved to the Quality Assurance Manual (QAM).

These details are not necessary to adequately describe the requirement (i.e.,reportingofsafetylimitviolation),arenot mandated by 10 CFR 50.36, and do not meet the criteria for retention in TS. Therefore, they can be moved to a licensee controlled document without an impact on safety. Administrative controls required by the Quality Assurance Program require all LERs, which include Safety limit violations, to be reviewed by both the offsite and onsite review and investigative functions.

Changes to the QAM will be controlled in accordance with 10 CFR 50.54. CTS moved to the QAM are administratively relocated details. They are identified by CTS number and a brief subject description in Appendix A.

Zion DOC A. 4. CTS 6.4 requires the Safety Limit violation to be reviewed by both the offsite and onsite review and investigative functions. This requirement is moved to the Quality Assurance Program, which requires all LERs, including Safety Limit violations, to be reviewed by both the offsite and onsite review and investigative functions. Since these details are also not necessary to adequately describe the pertinent regulatory requirement, they are not mandated by 10 CFR 50.36, and since they do not meet the criteria in the Final Policy Statement,-they can be moved to licensee controlled documents without an impact on safety.

Placing these details in controlled documents provides adequate assurance that they will be maintained. Changes to the Quality Assurance Manual will be controlled in accordance with 10 CFR 50.54. This change is consistent with NUREG 1431.

Discrepancy Current specifications 6.1.7.A.1 and 6.1.7.B.1 referred to in the NRC SER were removed from the CTS via the amendment process. The information areviously covered in these specifications now resides in Section 6.4 and tie NRC SER 1:\ data \riont sip \nt eser 2\r eview 2 \ attach,1 4 i

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i Attachment 1 DOC Technical Review should be changed accordingly.

NRC SER DOC 3.1 REACTIVITY CONTROL SYSTEMS CTS N/A M. 9. A shutdown action has been provided for when the upper Moderator Temperature Coefficient (MTC) limit is not restored. This change represents an additional restriction on plant operation to ensure safety analysis assumptions are maintained.

Zion DOC M. 9. Shutdown actions have been provided for when the upper and lower MTC limits are not restored. This change represents an additional restriction on plant operation necessary to ensure safety analysis assumptions are maintained.

Djjereoancy The Zion DOC and TS include shutdown actions when both the upper and lower MTC limits are not restored (LCO 3.1.4 Conditions A and C). The NRC SER should discuss shutdown actions for both the up' e t 4 the lower MTC limits.

NRC SER DOC 3.1 REACTIVITY CONTROL SYSTEMS CTS 3.2.1.C.1 M. 10. CTS 3.2.1.C.1 requires that the reactor core conditions at which the MTC is always more negative than TS 3.2.1.C.I.a be determined "immediately prior to startup." Neither the term immediately or startup is defined and compliance with this CTS is subject to wide interpretation. This requirement is more narrowly defined in the ITS by changing the Applicability to MODE I and MODE 2 with K ,

21.0. This change is consistent with NUREG-1431.

Zion DOC M. 10. The Moderator Temperature Coefficient (MTC) Specification Applicability has been changed from "Immediately prior to startup" to MODE I and MODE 2 with k, m 1.0 for the upper limit and Modes 1, 2, and 3 for the lower limit. The term "immediately" is vague and has been clarified by 3roviding a specified Applicability. As a result, the change for tie upper MTC limit is considered administrative in nature. The addition of a limitation and applicability for the lower limit which will be contained within 1:\ data \riontsip\nrcser2\ review 2\ attach _1 5 i

l Attachment 1 DOC Technical Review the Core Operating Limits Report (COLR) represents an additional restriction on plant operations necessary to ensure safety analysis assumptions are maintained. i Discrepancy The current DOC is confusing and provides justification for the addition of a lower MTC limit which was added under DOC 3.1-51. Accordingly, Zion DOC 3.1-10 needs to be revised. Attachment 4 provides a revised version of DOC 3.1 10.

NRC SER DOC 3.1 REACTIVITY CONTROL SYSTEMS M. 19. The Zion DOC is not discussed in the NRC SER.

Zion DOC 3.2.1.C.3, 3.2.1.D.1, 4.2.1.0 M. 19. Sequence and overlap limits have been added to the requirements of the LCO for control banks. In addition, a new Surveillance Requirement has been proposed which verifies the sequence and overlap limits specified in the COLR are met, every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , for control banks not fully withdrawn from the core. Periodic verification of the sequence and overlap limits, in addition to the insertion limits, help ensure the power distribution, ejected rod worth, SDN, and reactivity rate insertion assumptions used in the applicable safety analysis are preserved. This change represents an additional restriction on plant operations and is consistent with NVREG-1431.

Discrepancy The Zion DOC addresses technical information included in the TS and should be discussed in the NRC SER.

NRC SER DOC 3.1 REACTIVITY CONTROL SYSTEMS CTS 4.2.3.D.1.a L-A. 48. The identification of a specific method to perform this surveillance has been moved to plant procedures. This information provides details of design or process which are not directly pertinent to the actual Surveillance Requirement, but rather describe an acceptable method of compliance. Since these details are not necessary to adequately describe the actual regulatory 1:\ data \ziont sip \nr c ser 2\r eview2\a ttach_1 6

i Attachment 1 DOC Technical Review l

requirement, they can be moved to licensee controlled documents without a significant impact on safety. Placing these details in controlled docunients provides adequate assurance that they will be maintr.ined. Changes to plant procedures will be controlled in accordance with Zion plant procedures change process. This change is consistent with NUREG 1431.

Zion DOC L-A. 48. The identification of a specific method to perform this surveillance has been moved to the Bases. This information provides details of design or process which are not directly pertinent to the actual Surveillance Requirement, but rather describe an acceptable method of compliance. Since these details are not necessary to adequately describe the actual regulatory requirement, they can be moved to licensee controlled documents without a significant impact on safety. Placing these details in controlled documents provides adequate assurance that they will be maintained. 1he Bases will be controlled by the Bases Control Process in Chapter 5 of the proposed Technical Specifications.

This change is consistent with NUREG 1431.

Discrepancy The identification ci specific methods (i.e., excore detectors, thermocouples and/or incore detectors) to perform this surveillance outofservice)havebeenmovedtoplantproceduresas(describedintheNRCrod position with RPI SER. The Zion DOC needs to be changed accordingly. Additionally, the CTS mark up (p. 54) also has been changed to clarify that all of the indirect methods of rod position monitoring are addressed by the Zion DOC. The proposed changes to Zion DOC 3.1-48 are contained in Attachment 4.

NRC SER DOC 3.2 POWER DISTRIBUTION LlHITS CTS 4.2.2.B.I.b L-ll 36. The requirement 4.2.2.B.1.b has been revised as with Surveillance Requirement SR 3.2.4.2 which is performed once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the QPTR alarm is ino>erable. This Surveillance Requirement requires the use of tie a configuration and power. ppropriate instrumentation, Using the excore given (power range plant neutron flux), movable incore detectors, or core exit thermocouples, as appropriate, to verify the QPTR will provide the most accurate method available to calculate the QPTR limits and provide assurance that the appropriate limits are monitored and maintained 1:\ data \riont sip \nte ser 2 \r eview 2\ attach.1 7

Attachment 1 DOC Technical Review when the unit is in operation. Reducing the frequency from 4 times per shift is a less restrictive citange. The Frequency is

{ adequate to detect any relatively slow changes in QPTR, because for those cases of quadrant power tilt that occur quickly (e.g. a dropped rod), there typically are other indications of abnormality that prompt a verification of core power tilt. This change is an enhancement to CTS requirements and is consistent with NUREG-1431.

Zion DOC L ll. 36. CTS requirement 4.2.2.8.1.b has been revised as Surveillance Requirement (SR) 3.2.4.2, which is when the QPTR alarm is inoperable. QPTRperformed once every may be determined 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by the use of excore power range channels, moveable incore detectors (SR3.2.4.3),or core exit thermocouples (SR 3.2.4.4 . Using this equipment will provide appropriate monitoring of)QPTR limits when the unit is in operation. Reducing the frequency from four times per shift is a less restrictive change. However, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is adequate to detect any relatively slow changes in QPTR, because for those cases of quadrant power tilt that occur quickly (e.g. a dropped rod), there typically are other indications of abnormality that prompt a vertftcation of core power tilt. This frequency does not explicitly include that portion of the current frequency which requires such monitoring "after any load change greater than 10%," but the "once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months " frequency ensures that such monitoring will occur as soon as practical after such a load change. Therefore, this change is considered to be an administrative retention of current requirements. This change is consistent with NUREG-1431.

Discrenancy The Zion DOC addresses the fact that the 12 hr frequency does not explicitly include that portion of the current frequency which requires such monitoring after any load change greater than 10%. The NRC SER should discuss the acceptability of. the 12 hr frequency relative to monitoring QPTR after load changes. The Zion DOC has been modified to discuss this issue more clearly.

The proposed DOC is contained in Attachment 4.

NRC SER DOC 3.2 POWER DISTRIBUTION LIMITS CTSN/A L-12 37. A Note is added to 3roposed SR 3.2.4.1 and SR 3.2.4.2 that allows three power range ciannels to be used for calculating QPTR when one power range channel is inoperable, but only if THERMAL POWER 1:\ data \riont sip \nte ser 2\r eview 2\at tach _1 8

Attachment 1 DOC Technical Review 1 is below 75% RTP. With an Nuclear Instrumentation System [NIS) power range channel inoperable, tilt monitoring for a aort 90n of ;

the reactor core becomes degraded. Large tilts are 11(ely ;

detected with the remaining channels before they are sufficient to result in exceeding a peaking factor limit from below 75% RTP, but the capability for detection of small power tilts (which may result in exceeding a peaking factor limit when above 75% RTP) in some quadrants is decreased. Therefore, use of only three '

detectors is limited to < 75% RTP. This is a less restrictive change because the permissive does not exist in CTS. It is acceptable, however, because the risk of a plant shutdown transient is avoided without impact on safety. Therefore, this change is an enhancement to CTS requirements and is consistent with NVREG 1431.

Zjon DOC L-12, 31. A Note is added to 3roposed SR 3.2.4.1 and SR 3.2.4.2 that allows three power range clannels to be used for calculating QPTR when one power rango channel is inoperable, but only if THERMAL POWER is below 75% RTP. With an NIS power range channel inoperable, tilt monitoring for a portion of the reactor core becomes degraded. Large tilts are likely detected with the remaining channels before they are sufficient to result in exceeding a Safety Limit from below 75% RTP, but the capability for detection of small power tilts (which may result in exceeding a Safety Limit when above 75% RTP) in some quadrants is decreased. Therefore, use of only three detectors is limited to < 75% RTP.

Discrepancy The term peaking factor limit more specifically describes the variable of concern in this Specification. The more generic Safety Limit has been replaced with peaking factor limit in the Zion D0C. This proposed change has been included in Attachment 4.

NRC SER DOC 3.2 POWER DISTRIBVTION LIMITS CTS 3.2.2.C.2 and 4.2.2.C.2 A. 38. The allowance to monitor QPTR with incore thermocouples if an excore power range channel is inoperable is retained (CTS 3/4.2.2.C.2). This is an administrative retention of current requirements.

1:\ data \riont sip \nt eser 2\r eview 2\at tach _1 9

Attachment 1 DOC Technical Review Zion DOC A. 38. The allowance to monitor QPTR with incore thermocouples if an excore power range channel is inoperable is retained (CTS 3/4.2.2.C.2). The core exit thermocouples can be used to confirm that the normalized symmetric power distribution is consistent l with the indicated QPTR and any previous data indicating a tilt i just as the excore and movable incore detectors are used. The i

core exit thermocouple monitoring is performed with at least four l thermocouples in each quadrant (symmetrically located) using the calculated enthalpy rise associated with them. The thermocouple enthalpies are corrected to match the assembly powers from a recent flux map. Using this method, the tilt indicated by the core exit thermocouples will be a complete tilt (as indicated by a flux map), and not a "zerced" tilt as provided by the excore detectors. Therefore, it is inappropriate to apply the excore QPTR limits directly to the indicated core exit thermocouple tilt.

Consistent with the intent of QPTR measurements, a target value for core exit thermocou)1es is established for each quadrant and routinely verified, suc1 that when the core exit thermocouples are used a current target tilt value is available to be subtracted from the current indicated core exit thermocouple tilt (like the process to determine-tilt using the excore detectors). The limits of LC0 3.2.4 are then applied to the difference between these tilt values. This method has been successfully applied at Zion since original issuance of the operating license. The Frequency is retained as within one hour and once per hour thereafter. This does not explicitly include that portion of the current frequency which requires such monitoring "after any load change greater than 10%," but the "once per hour" ensures that such monitoring will occur as soon as practical after such a load change. Therefore, this change is considered to be an administrative retention of current requirements.

Discrepancy ,

The Zion DOC addresses the fact that the once per hour frequency does not exolicitly include that portion of the current frequency which requires such monitoring after any load change greater than 10%. The NRC SER should discuss the acceptability of the once per hour frequency to ensure that such monitoring will occur as soon as practical after such a load change.

1:\ data \riontsip\nteser2\ review 2\ attach,1 10

l Attachment 1 DOC Technical Review NRC SER DOC 3.3.1 RTS INSTRUMENTATION I CTS Table 3.1-1

11. The following changes are related to CTS Table 3.1.1. The changes are in format only and are intended to simplify and clarify the information to the operators. !

l A. The "No. of Channels" column (Column 1) is changed to " Required Channels." With less than the required channels available for a l i

Function, a Condition with the appropriate Required Actions is now l specified on the new Table 3.3.1-1.

B. The " Minimum OPERABLE Channels" and " Minimum Degree of Redundancy" columns are eliminated from Table 3.1-1. This information including Note 4++ is now incorporated into the Conditions provided for each Function. Notes are provided in each Condition, where appropriate, to allow testing when a channel is inoperable.

These Notes specify the time allowed for testing. New actions allow continued operation with a single channel inoperable.

CTS Table 3.1 1 Column 1

11. The following change is related to CTS Table 3.1.1. The change is in format only and is intended to simplify and clarify the information to the operators.

L.A. The "No. of Channels to Trip" column is eliminated from the Table and discussed in the Bases for each Function. This information provides details of design or process which are not directly pertinent to the actual requirement. Since these details are not necessary to adequately describe the actual regulatory requirement, they can be moved to licensee controlled documents without an impact on safety. Changes to the Bases will be controlled using the Bases Control Program (5.5.12) in Section 5 of the Technical Specifications. CTS moved to the Bases represent administrative 1y relocated details. They are identified by CTS number and a brief subject description in Appendix A.

Discrepancy The discussion fil introductory paragra)h appears twice under Section 3.3.1 in the NRC SER. The second occurrence of tie discussion #11 introductory paragraph should be eliminated from the NRC SER.

Also, there is no B. category for DOCS. The Zion DOC is concerned with an administrative change, and, therefore, the discussion should be designated as A. in the NRC SER.

IMata\riontsip\nrcser2\ review 2\ attach,1 11

Attachment 1 DOC Technical Review NRC SER DOC 3.3.1 RTS INSTRUMENTATION CTS Table 3.1-1 Item 6.b

18. Source Range Neutron Flux

-L1 The CTS requirement to immediately verify shutdown margin if a L-2 source range channel is inoperable is deleted. Now, in MODE 2 and i MODES 3, 4, and 5 with the Rod Control System capable of rod withdrawal, an Action is provided to open the Reactor Trip Breakers (RTB) immediately in the event of an inoperable source range channel. This change is acceptable because this Action ensures the unit is put in the most stable condition possible under the circumstances. Upon opening the RTBs the unit enters a condition where the source range channels provide a monitoring function only. If the required source range channel is not returned to an OPERABLE status, the actions require operations involving positive reactivity additions to be suspended, unborated water sources to be isolated and the performance of a Shutdown Margin calculation. This change is consistent with NUREG 1431.

Zion DOC

18. Source Range Neutron Flux L-1.

In MODE 2 and MODES 3, 4, and 5 with the Rod Control System capable L 2. of rod withdrawal, an Action is provided to open the RTBs immediately in the event of an inoperable source range channel.

This Action ensures the unit is put in the most stable condition possible under the circumstances. Upon opening the RTBs the unit enters a condition where the source range channels provide a monitoring function only. If the required source range channel is not returned to an OPERABLE status, the actions require operations involving positive reactivity additions to be suspended, unborated water sources isolated and the performance of a Shutdown Margin calculation.

Discrepancy The CTS requirement to immediately verify shutdown margin if a source range channel is inoperable is addressed in the proposed rewrite of Discussion of Change (DOC) 3.1-36. Based on the revised DOC 3.1-36, reference to deletion of shutdown margin verifications should be deleted from this SER discussion, h\ data \rlontsip\nteser2\ review 2\ attach _1 12 S-7\ _

Attachment 1 DOC Technical Review NRC SER DOC 3.3.1 RTS INSTRUMENTATION L-1 19. The Zion DOC is not discussed in the NRC SER.

Zion DOC

19. Intermediate Range Neutron Flux L 1.

With THERMAL POWER below the P-( setpoint, source range instrumentation performs the monitoring and protective functions.

However, the intermediate range instrumentation must be OPERABLE when power level is-above the P 6 setpoint and below the capability of the power range instrumentation (10%). Therefore, the intermediate range channel is only required above the P 6 setpoint and below the P-10 setpoint.- If between P 6 and P-10, and one intermediate range channel becomes inoperable, an action has been provided to immediately suspend operations involving positive reactivity additions and to decrease power < P 6. This action places the unit in a condition where the source range instrumentation provides the required protection and the intermediate range instrumentation is no longer required.

Discrenancy The Zion DOC addresses technical information included in TS and should be discussed in the NRC SER. However, DOC 3.3.1 19 has been rewritten to clarify the change that is being proposed. This revision has been included in Attachment 4.

MRC SER DOC 3.3.1 RTS INSTRUMENTATION

-L-2 20. The Zion DOC is not discussed in the NRC SER.

Zion DOC ~

20. Overtemperature AT and Overpower AT L-2. -*- The Actions have been revised to be consistent with NUREG 1431, including the applicable changes of WCAP-10271 and its supplements. The Actions allow 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to place the inoperable channel in trip. Four hours are allowed for bypassing an inoperable channel for surveillance testing of other channels. A total of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months are allowed to be in MODE 3. The Actions and allowed outage times are justified in WCAP-10271 and its 1:\deta\alontsip\necaer2\teview2\sttach_1 13

=

Attachment 1 DOC Technical Review supplements. WCAP 10271 has been reviewed and approved by the NRC. The CTS requirement to place the unit in CSD if the minimum conditions are not met has been deleted. The Overtem>erature AT and Overpressure AT functions provide protection whici ensures the integrity of the fuel pellets. In MODES 3, 4, 5, or 6 these trip functions do not have to be OPERABLE because the reactor is not operating and there is insufficient heat production to be concerned with DNB.

Discrecancy The Zion DOC addresses technical information included in TS and should be discussed in the NRC SER.

NRC SER DOC 3.3.1 RTS INSTRUMENTATION L-1 35. The Zion DOC is not discussed in the NRC SER.

Zion DOC 3.1.1 T3.1-1 Note **

L-1, 35. The time to reach MODE 3 (Hot Shutdown) has been extended from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This provides the necessary time to shutdown the unit in a controlled and orderly manner that is within the capabilities of the plant assuming the minimum required equipment is OPERABLE. This extra time reduces the potential for a plant transient that could challenge safety systems. This time is also consistent with NUREG 1431 and proposed LCO 3.0.3.

Discrepancy The Zion DOC addresses technical information included in TS and should be discussed in the NRC SER.

NRC SER DOC 3.3.1 RTS INSTRUMENTATION CTS Table 3.1 1, Note til A. 36. The Actions required by this Note, for the source range instrumentation, have been incorporated into the applicable Actions for this instrument Function (See Discussion #18 above).

This is consistent with NUREG 1431 and represents a format change only.

I:\ data \riont sip \nt e ser 2 \ review 2\ attach _1 14

Attachment 1 DOC Technical Review Zion DOC A. 36. The Actions require 1 by this Note, for the source range instrumentation,: have been incorporated into the applicable ,

Actions for this instrument Function. (See DOC #18 for Source 1 Range Neutron Flux). This is consistent-with NUREG 1431 and represents a format change only, i Discrenancy ;

Both the Zion DOC and the NRC SER nesi to be enhanced to address the fact that the CTS requirement to verify shutdomi margin if a source range channel is .

inoperable has beer changed- from "immediately" in CTS to "once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months "

- in TS (see LC0 3.3.1 Required Action B.3). This is a relaxation of the CTS requirement, and, therefore, the categorization of the Zion DOC needs t, ce changed from "A" to "L." The proposed DOC is contained in Attachment 4.

Finally, the discussion should be moved from Section 111.2 to Section III.3 in the NRC SER. >

NRC SER DOC 3.3.1 RTS INSTRUMENTATION CTS Table 4.1-1. Items 2,3,4, and 5

41. ' Power Range Neutron Flux Instrumentation The Surveillance Requirements for these instrument channels have !

been reorganized and revised to be consistent with NUREG-1431.

t A. The daily heat balance calibration (0 8) is changed to SR 3.3.1.2 l and assigned to the Power Range Neutron Flux High Function. This i Surveillance need only be noted for one power range instrument

Function as the adjustments performed affect the detector output -

and consequently all the power range Functions. Assigning this test to a single power range Function is an administrative change .

l that confoms to NUREG-1431. l l A. The daily heat balance Surveillance Requirement-is clarified by -

1. requiring a comparison to and adjustment of the excore instrumentation if the absolute difference is >2%. This change is consistent with the Zion interpretation of CTS and the-Zion 4 General Operating Procedures. This change is an administrative correction and is consistent with NUREG 1431.

[ A. A' Note modifies proposed SR 3.3.1.2 by stating that the Surveil-j lance-is not required to be performed.until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reaching 40% RTP. The 40% RTP requirement is necessary due to the IMeta\alontsip\ntcser2\ review 2\sttach ,1 15_ !

4

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1 Attachment 1 DOC Technical Review inaccuracy of the calorimetric below this power. The 40% RTP requirement is consistent with the Zion interpretation of CTS and conforms to the Zion General Operating Procedures for the first calorimetric when escalating power. The 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed to perform this Surveillance is a reasonable time and is consistent with the CTS interpretation of one shift.

A. The incore in excore axial imbalance comparison (EFPN') is changed to SR 3.3.1.3. ThissurveillanceverifiestheF(AI)inputtothe Overtemp9rature AT Function. As such, this SR has been assigned to the Overtemperature AT Function. Assigning this test to the Overte'Aperature AT Function is an administrative change that conforms to NUREG 1431.

Zion DOC

41. Power Range Neutron Flux Instrumentation The Surveillance Requirements for these instrument chann n. have been reorganized and revised to be consistent with NUREG 1431.

A.

The daily heat balance calibration (D') is changed to SR 3.3.1.2 and assigned to the Power Range Neutron Flux High function. This Surveillance need only be noted for one power range instrument Function as the adjustments performed affect the det1ctor output and consequently all the power range Functions. Assigning this test to a single power range Function is an administrative change that conforms to NUREG-1431.

A.

The daily heat balance Surveillance Requirement is clarified by requiring a comparison and adjustment if the absolute difference is >2%. This Surveillanu is technicai'y not a CHANNEL CAllBRATION. This change is an *d inistrative correction and is consistent with NUREG-1431.

A.

A Note modifies proposed SR 3.3.1.2 by stating that the Surveil-lance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after' reaching 40% RTP. The 40% RTP requirement is necessary due to the inaccuracy of the calorimetric below this power. The 40% RTP requirement conforms to the Zion General Operating Procomiures for the first calorimetric when escalating power. The 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed to perfom this Surveillance is a reasonable time and is consistent with the CTS interpretation of one shift. This change does not impose any additional restrictions on plant operation.

A.

The incore to excore axial imbalance comparison (EFPM') is changed to SR 3.3.1.3. -This surveillance verifies the fi (al) input to the IMata\alontsip\nrcser2\ review 2\sttach 1 16

Attachment 1 DOC Technical Review Overtemperature AT Function. As such, this SR has been assigned to the Overtemperature AT Function. Assigning this test to the Overtemperature AT Function is an administrative change that conforms to NUREG 1431.

Discrenancy f,(AI) is the designation used for the input to the Overtemperature AT Function in TS Table 3.3.1 1 Note 1. The NRC SER should be changed to include the f,(AI) designation.

NRC SER DOC 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION (ESFAS) INSTRUMENTATION CTS Table 3.4 1 Item IV.4 A. 37. Steam Line Isolation Low Steam Line Pressure The minimum OPERA 8tE channel requirement has been revised from 3 to be consistent with NUREG-to 1 per 1431. steam Since lineActions the new (total of four)llow also a .

continued operation with one channel inoperable as in the CTS, this change is purely administrative.

Zion DOC

37. Steam Line Isolation - Low Steam Line Pressure A. a. The ninteJe OPERA 8LE channel requirement has been revised from "3" to "I per steam line" (total of four) to be consistent with NUREG-1431. Since the new Actions allow continued operation with one channel inoperable, this change is administrative in nature.

A. c. The time constants for the lead / lag controller reference in NUREG-1431 are generic industry numbers. The Zion-specific setpoints are 10 sec. for lead, and 1.8 sec, for lag. Setpoints have i 1%

established tolerances for instrument channel and setpoint errors.

Discrenancy Both Parts A & C of the Zion D00 address technical information included in TS,

-but only Part A is discussed in the NRC SER. Both Parts. A & C of the Zion DOC should be discussed in the NRC SER.

-NRC SER DOC 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION (ESFAS) INSTRUMENTATION 40.c. The format of this function has been revised to be consistent with the presentation contained in NUREG-1431. AFW Automatic Actuation 1:\dete\alontsip\ntcset2\teview2\ettech_1 17

Attachment 1 DOC Technical Revie';

Logic consists of relay and contact actuation developed in the circuitry of the auxiliary feed pump cointrol circuits. Input signals are derived from the steam generator water level Low Low function and the reactor coolant has Undervoltage Function.

Zion DOC A. c. The format of this function has been revised to be consistent with the presentation contained in NUREG 1431. AFW Automatic Actuation Logic consists of relay and contact actuation developed in the circuitry of the auxiliary feed pump control circuits. Input signals are derived from the Steam Generator Water Level Low low function, and the Reactor Coolant Bus Undervoltage function.

Discrepancy The NRC SER should be corrected to read Reactor Coolant Bus.

NRC SER DOC 3.3.2 ENGINEERED SAf.ETY FEATURES ACTUATION (ESFAS) INSTRUMENTATION M. 72. The Zion DOC is not discussed in the NRC SER.

Zion DOC CTS Page 131 (Table 3.4-1 Permissives)

M. 72. Condition Q. was modified to include an additional condition to entar Required Action Q.1 if one or more interlocks with two Channels are inoperable. This is to address the case where a failure of a single interlock channel causes the interlock function to be inoperable. This requires the interlock to be in its required state within one hour. If this cannot be met, Required Actions R.1 and R.2 require plant shutdown, thus all possible failure modes of the interlock functions are addressed.

Discrepansy The Zion DOC addresses technical information included in the TS and should be discussed in the NRC SER.

NRC SER DOC 3.3.3 POST ACCIDENT MONITORING (PAN) INSTRUMENTATION CTS 3.8.8.B. Action 1 and 3.8.9 Action a L-2 4. Proposed Condition A allows 30 days to restore a required PAM channel to OPERABLE status. Condition B applies when the Required 1:\ data \riontsip\ntcser2\ review 2\ attach 1 18

Attachment 1 l DOC Technical Review Action and associated Completion Time of Condition A are not met.

Required Action B.1 specifies action to be initiated in accordance with proposed Specificatian 5.6.7 (PAM Report). This Action allows continued operatio with one PAM instrument channel inoperable provided an adequate alternate method of monitoring the parameters is identified and justified in a special report to the NRC, and is implemented. For the instruments listed in CTS Table 3.8.9-1, this represents a relaxation from the requirement to be in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . For the containment hydrogen monitors, this represents a relaxation from the requirement to be in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The proposed action to submit a report in lieu of the shutdown requirements is acceptable based on the small probability of an event requiring the PAM instrumentation and the alternate means of monitoring the affected parameter. Providing this proposed action will minimize the potential for plant transients that can occur during plant shutdown. This change is consistent with NUREG 1431.

Zion DOC L-2. 4. Proposed Condition A allows 30 days to restore a required PAM channel to OPERABLE status. Condition B applies when the Required Action and associated Completion Time of Condition A are not met.

Required Action B.1 specifies action to be initiated in accordance with proposed Specification 5.6.7 (PAM Report). This Action allows continued operation with one PAM instrument channel inoperable provided an adequate alternate means of monitoring the parameters are identified and justified in a special report to the NRC. For the instruments listed in CTS Table 3.8.9-1, this represents a relaxation from the requirement to be in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . For the containr.ent hydrogen monitors, this ripresents a relaxation from the requirement to be in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The proposed action to submit a re) ort in lieu of the shutdown requirements is acceptable based on tie small probability of an event requiring the PAM instrumentation and the alternate means of monitoring the affected parameter. The alternate means of monitoring must be established to utilize the provisions of the proposed actions. Providing this proposed action will minimize the potential for plant transients that can occur during plant shutdown.

Discrepancy The NRC SER imposes the additional condition that the alternate means of monitoring is actually implemented. The Zion DOC and TS require that the alternate means of monitoring be identified and justified in a special report.

t h\ data \riont sip \nrc ser 2\r eview 2\att ach_1 19 I

I Attachment 1 DOC Technical Review Since the alternate means could actually be implemented only during accident conditions, identification and justification of means e e all that is required during normal operations. The words and is implemented should, therefore, be deleted from the NRC SER.

NRC SER DOC 3.3.5 LOSS OF POWER (LOP) DIESEL GENERATOR (DG) START INSTRUMENTAT10N A. 5. The Zion DOC is not discussed in the NRC SER.

Zion DOC A. 5. In the CTS, the setpoint for Station Blackout is " Time Dependent on Voltage". In Zion Station's proposed Section 3.3,

" Instrumentation" Allowable Values are specified for various 1nstrument functions where applicable. When an analytical limit does not exist for a given Function, the Allowable Value is based on a plant specific evaluation of the functional requirement for the affected channel. In the case of the Station Blackout Function there is no analytical limit since the pur)ose of the relay is to detect a total loss of voltage. As suc1, the Allowable Values specified are based on an engineering evaluation.

Discrepancy The Zion DOC addresses technical information included in TS and should be discussed in the NRC SER.

NRC SER DOC 3.3.6 CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION M. 1. The Zion DOC is not discussed in the NRC SER.

Zion DOC CTS Page 251 M. 1. LCO 3.3.6, Containment Ventilation Isolation Instrumentation, has been added to the Technical Specifications, consistent with NUREG-1431. This change represents an additional restriction to plant operations. The Bases for proposed LC0 3.3.6 provides additional information regarding this Specification. The Containment Ventilation Isolation Instrumentation Specification ensures the OPERABILITY of the instruments required to prevent the release of radioactivity to the environment through containment penetrations which provide direct access to the environment. As h\ data \ziontsip\nteser2\ review 2\ attach,1 20

.. .. - _ - _ I

Attachment 1 DOC Technicai Review such, for completeness of instrumentation which perform this function, the Containment Purge Radiation Monitor has been included in proposed Table 3.3.6-1. Appropriate Actions and Surveillance Requirements have been added address the radiation instrument function and the manual initiation function.

Discrepancy The Zion DOC addresses technical information included in the TS and should be discussed in the NRC SER.

NRC SER DOC 3.3.8 FUEL HANDLING BUILDING EMERGENCY FILTRATION SYSTEM (FHBEFS)

ACTUA110N INSTRUMENTATION CTS Table 3.141 Item 1.A.2 and Action 21 L A. 7. The Applicability of this Specification has been modified to remove the requirement for system OPERABILITY during operation of the crane with heavy leads. System OPERABILITY during movement of heavy loads was required to cope with the consequences of dropping heavy loads on irradiated fuel. However, administrative controls are in place at Zion that preclude the movement of heavy loads over irradiated fuel. These administrative controls are consistent with NUREG 0612, " Control of Heavy Loads at Nuclear Power Plants (7/80)," and are described in the UFSAR. Use of administrative controls for movement of heavy loads has been found acceptable by the staff as stated in GL-85 11. GL 85-11 concludes in part, that administrative controls are in place and are sufficient such that heavy loads considerations limits to the extent practicable the risks associated with handling heavy loads, and no additional licensing requirements are warranted. Based on the above, the staff concludes that the proposed change is acceptable. System OPERABILITY will continue to be required during Core Alterations and during movement of irradiated fuel.

Zion DOC L-A. 7. The Applicability of this Specification has been modified to remove the need for system OPERABILITY during the operation of the crane with loads over irradiated fuel in the fuel building. This is based on the administrative controls to address the movement of any heavy load in the fuel handling building. This information provides details of design or process which are not directly pertinent to the actual requirements, i.e., Limiting Condition for Operation or Surveillance Requirement, which support the safety analysis but rather describe en acceptable method of compliance.

1:\ data \riont sip \nrc ser 2 \r eview 2\a ttach_1 21

{

1 .

I Attachment 1 DOC Technical Review These details will be moved to the UFSAR. Placing these details in the UFSAR provides adequate assurance that they will be maintained. These administrative controls provide assurance that the equivalent level of safety is provided as exists in the existing Technical Saecifications. The controls also assure that the analyzed DBA is >ounding for any )otential accidents in the fuel handling building. Changes to tle UFSAR will be controlled by 10 CFR 50.59. This change is consistent with NUREG-1431.

Discrepann The NRC SER discussion of DOC 3.3.8-7 was enhanced in dialog between NRC and Comed subsequent to the submittal of DOC 3.3.8-7. The proposed DOC is contained in Attachment 4.

NRC SER DOC 3.4 REACTOR COOLANT SYSTEM CTS N/A L-18, 71. CTS 4.3.2.G l.a requires performance of a CHANNEL FUNCTIONAL TEST, excluding valve operation, on the PORV actuation channel within 31 days prior to entering a condition in which the PORV is required OPERABLE. This Specification creates unnecessary scheduling burdens and resource expenditures, and establishes the potential for missed surveillance during unplanned shutdowns. A Note has been added to the ITS to allow entry into the Mode of applicability for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to performing the surveillance. Without this note, the SR would have to be performed or verified performed even though the units is not in the Mode of Applicability. This creates an unnecessary resource burden on the Station, and if not performed could lead to an increased potential for a missed surveillance, Technical Specification noncompliance, and delays in plant u.atdown actions.

This note will facilitate scheduling performance of the SR without impacting plant activities and reduce the potential for 'nissed surveillances and delays in plant cooltiown actions. This change is consistent with NU1EG-1431.

lion DOC L-18, 71. CTS 4.3.2.G.I.a requires performance of a CHANNEL FUNCTIONAL TEST, excluding valve operation, on the PORV actuation channel within 31 days prior to entering a condition in which the PORV is required OPERABLE. A Note has been added to the ITS to indicate that SR 3.4.12.8 is required to be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 1:\ data \ziontsip\nteser2\ review 2\ attach _1 22 y . -

Attachment 1 DOC Technical Review l

decreasing RCS cold leg temperature to less than or equal to the LTOP enable temperature specified in the PTLR. The Note allows entry into the LTOP Mode of Applicability prior to reaching conditions acceptable to perform the SR. Since the PORVs are required to be OPERABLE (with lift settings for full operating pressure) in MODES 1, 2, and 3, it is less of a challenge to plant operation to perform the COT until the plant is in the LTOP Mode of Applicability, when the PORV lift setpoint can be reduced to the L.JP setting. The test must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering the LTOP MODES.

Discrepancy c3 The NRC SER discussion of DOC 3.4-71 was enhanced in dialog between NRC and Comed subsequent to the submittal of DOC 3.4-71. The Zion DOC has been changed to address these enhancements and is included in Attachment 4.

ERC SER DOC 3.6 CONTAINMENT SYSTEMS A. 14. The Zion DOC is not discussed in the NRC SER.

Zion DOC A. 14. In CTS 3.6.1.C, the number of fan coolers required to be OPERABLE has been increased from "four" to "five". The justification for this increase has been provided in discussion #1 of this attachment.

Djicrepancy The Zion DOC adiresses technical information included in TS and should be discussed in the NRC SER. This DOC is categorized as an " Administrative" change, but this change reflects a more restrictive require. Accordingly the classifications has been changed to "M". This proposed change is included in Attachment 4. Also, the reference in the Zion DOC to discussion #1 of this attachment should be changed in the NRC SER to read discussion #1 of Section III.4 of this attachment since discussion #1 is categorized as a more restrictive change and, therefore, is physically located in Section III.4.

NRC O'R 000 3.7 PLANT SYSTEMS CTS 3.13.2.A L-A. 38. The Applicability of this Specification has been modified to remove the requirement for system OPERABILITY during the operation 1:\ data \ziontsip\nrcser2\ review 2\ attach _1 23

[

Attachment ~ 1-DOC Technical Review

- of the crane with loads over irradiated fuel in the fuel building.

-System OPERABILITY during movement-heavy loads was required to cope with the consequences of dropping heavy loads on irradiated fuel. However, administrative controls are in place at Zion that preclude the movement of heavy loads over irradiated fuel. These administrative controls are consistent with NUREG-0612, " Control of-Heavy Loads at Nuclear Power Plants," and are described in the UFSAR. Use of administrativt controls for movement of heavy loads has been found acceptable by the staff as stated in GL 85-11.

GL 85-11 concludes, in part, that administrative controls are in place and are sufficient such that heavy loads considerations '

limits, to the extent practicable,- the-risks. associated with handling heavy loads, and no additional licensing requirements are warranted. Based on the above, the staff-concludes that the pro >osed change is acceptable. System OPERABILITY will continue to se required during movement of irradiated fuel.

Zion DOC L-A. 38. The Applicability of this Specification has been modified to remove the need for system OPERABILITY during the operation of the crane with loads over irradiated fuel in the tuel building. This is based on the administrative controls 1to address the movement of any heavy load in the fuel handling building. This information provides details of design or process which are not directly-pertinent to the actual requirements, i.e., Limiting Condition for Operation or Surveillance Requirement, which support the safety analysis but'rather describe an acceptable method of compliance.

These details will be moved to the UFSAR. The controls also assure;that the analyzed DBA is bounding for any potential accidents in the fuel handling building. Since these details are not necessary to adequately describe the actual regulatory requirement, they can be moved to' licensee controlled documents without a impact on safety. -Placing these details in controlled documents provides-adequate assurance that they will be maintained. Changes to these details will be controlled by 10 CFR 50.59. 'This change is consistent with NUREG-1431. I Discrecancy-The Zion DOC has- been changed to specifically address material relocated to plant procedures. The revised Zion. DOC is included in Attachment 4. The discussion of this DOC ih the NRC SER should be amended to address the relocated material also.

1:\ data \riontsip\ntcser2\ review 2\ attach _1 24

_.___.__t

Attachment 1 DOC Technical Review NRC SER DOC 3.7 PLANT SYSTEM 3 M. 43. A new Surveillance Requirement (SR 3.7.13.1) has been added to LCO 3.7.13 to verify that the ventilation system is operable during the period of time the Shield Wall or Equipment Hatch is not intact. This is done by verifying that a ventilation spool piece has been installed between the Auxiliary Building and Pipe Tunnel, '

such that no ventilation flow path exists from the FHBEFS to the i Pipe Tunnel.

Zion DOC M. 43. A new Surveillance Requirement (SR 3.7.13.2) has been added to LCO 3.7.13 to verify that the ventilation system will correctly function in the post-accident mode of operation during the period of time the Shield Wall is not intact. This is done by verifying that a ventilation spool piece has been installed between the Auxiliary Building and Pipe Tunnel, such that no ventilation flow path exists from the FHBEFS to the Pipe Tunnel.

Discrepancy The correct designator for the new Surveillance Requirement is SR 3.7.13.2 and the NRC SER should be changed accordingly.

NRC SER DOC 3 7 PLANT SYSTEMS CTS 4.17.1.B M. 52. Additional Surveillance Requirements have been provided. SR 3.7.9.3 was added to ensure that the system actuates on an actual or simulated actuation signal. SR 3.7.9.4 was added to ensure that the system can maintain appropriate building pressures during the emergency mode. This change represents an additional restriction on plant operation to ensure the OPERABILITY of the CREFS, Zion DOC M. 52. Additional Surveillance Requirements have been provided. SR 3.7.9.3 was added to ensure that the system actuates on an actual or simulated actuation signal. SR 3.7.9.4 was added to ensure that the system can maintain appropriate building pressures during the emergency mode. This change represents an additional restriction on plant operation necessary to ensure the OPERABILITY of the CREFS. A Note has been added to SR 3.7.9.3 that indicates 1:\ data \riontsip\nrcser2\ review 2\ attach _1 25

Attachment 1 DOC Technical Review automatic actuation is not required when CREFS is operating.

Automatic actuation signals that are inoperable require CREFS to be put in service, thus fulfilling the safety function of the system. Therefore a failure of SR 3.7.9.3 from a failure of the automatic actuation signals does not require CREFS to be declared inoperable.

Discrepancy The Zion DOC addresses a Note that has been added to TS clarifying CREFS o)erability when the automatic actuation signals are inoperable. The NRC SER s1ould discuss the acceptability of this Note.

NRC SER 000 3.8 ELECTRICAL POWER SYSTEMS CTS 3.15.2.0 Note' L-10. 39. CTS Requirement:

The CTS requirement for a 7-day outage time for (0) or common DG under specific circumstances is being changed to allow a 7-day outage for the (0) DG at all times. The common diesel generator

((0) DG) is shared between Unit I and Unit 2. The current Technical Specifications allow a 7-day outage time for an inoperable (0) DG on an operating unit only under specific circumstances.

The 7-day A0T for the (0) DG is necessary in order to avoid dual unit outages when performing maintenance and testing on the (0)

DG which typically takes longer than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Periodic maintenance is necessary to maintain an acceptable level of DG reliability. Maintenance and testing required for the DG typically requires a total time period of 14 days, based on recommendations provided by the diesel generator manufacturer, and Technical Specification Surveillance Requirements. In order to perform all the required work within the Technical Specification 7 day period, the work is segmented into multiple work periods.

These are typically 7 days periods and are associated with refueling outages.

In the CTS the common DG may be taken out of service for up to seven days with one unit in Mode 1, 2, 3, or 4 providing the following limitations are met:

1) the common diesel generator is made inoperable for maintenance and testing 1:\ data \ziontsip\nteser2\ review 2\ attach _1 26

Attachment 1 DOC Technical Review l

2) one unit is in MODE 5 or 6,

3) three remaining diesel generators are OPERABLE (two OPERABLE f on the operating unit and one OPERABLE on the unit in MODE 5 I or6),

4) the three remaining OPERABLE diesel generators shall be demonstrated OPERABLE by performance of Surveillance Requirement 4.15.1.B.2 within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months prior to removal of the common diesel (0) from service,

5) prior to taking the common diesel generator (0) out of service, verify that at least three service water pumps and three component cooling water pumps are OPERABLE with their associated emergency power supplies.

6) during the 7 day period, the three remaining OPERABLE diesel generators shall be verified OPERABLE daily, in addition to any testing required by Surveillance Requirement 4.15.1.B.2,

7) during the 7 day period, for the unit in MODE 5 or 6, no mid-loop or reduced-RCS inventory operations, as defined in NRC Generic letter 88-17, will be performed while fuel is in the vessel,

8) in the event one or more diesel generators (other than the common diesel generator (0)) for the operatirg unit becomes '

inoperable, the operating unit will be brought to MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 5 within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , and

9) in the event two diesel generators (other than the common diesel generator (0)) on the unit in Mode 5 or 6 become inoperable, the operating unit will enter Actions 3.15.2.0 and 3.0.5.

ITS Proposal:

The 7-day limit is being proposed to be independent of opposite unit operating condition, with the application restrictions deleted or addressed within the Technical Specification in a differing form as addressed below. This change cannot in and of itself be considered separate of the changes implemented throughout the ITS. The ITS has addressed shared system interrelationship, requiring more equipment for operational and shutdown modes than the current Technical Specifications (CiS) 1:\ data \ziontsip\nrcser2\ review 2\ attach _,1 27

Attachment 1 DOC Technical Review i

require. That taken in conjunction with programs such as the Safety Function Determination Program, and heightened redundant component verification, will preserve the minimum number of systems and components necessary for event mitigation consistent with analysis assumptions. As addressed below, and taken in the aggregate, application of a 7 day restoration period for the coamon diesel generator, independent of the operational mode of a second unit, does not result in a decrease in overall plant safety.

1) The common diesel generator is made inoperable for maintenance and testing The current requirement allows applying the 7 day limit only to testing and preplanned maintenance. In the ITS proposal, the 7 days is being provided for any reason the diesel is found to be inoperable. The effect of an inoperable DG on overall plant safety is independent of the reason the DG is inoperable. Therefore, if it is acceptable for the (0) DG to be inoperable for 7 days for maintenance, it is acceptable for the DG to be inoperable for 7 days for any reason. Moreover, the only reason the (0) DG would be inoperable for extended periods (i.e., 7 days) would be for preventive or corrective maintenance. Since the CTS does not identify any specific type of maintenance, the CTS is effectively without meaning. The CTS constraint is, therefore, deleted. Systems required to be operable which are supported by the diesel generator will be evaluated in accordance with the Safety Function Determination Program and redundant component verifications required by ITS LC0 3.8.1, thereby maintaining Technical Specifications required functions.

2) one unit is in MODE 5 or 6, The Service Water (SW) and Component Cooling (CC) systems are common to both units at Zion. Shared system interrelationships have been addressed in the ITS such that the minimum number of component necessary to mitigate an accident in one unit while supporting controlled shutdown or maintaining shutdown conditions on the opposite unit are preserved. The systems and components required to be operable in the ITS are consistent with the minimum required number of systems and components necessary for event mitigation. The safety function determination program, in conjunction with redundant component verifications contained I:\ data \ziontsipinrcser2\ review 2\ attach _1 28

_______-____J

Attachment 1

, DOC Technical Review 1

with LCO 3.8.1 (which must be met for both units) will preserve this minimum number of components required for event mitigation. Therefore, operation under a limited duration is not affected by the operational mode of the other unit.

3) three remaining diesel generators are OPERABLE (two OPERABLE .

on the operating unit and one OPERABLE on the unit in MODE 5 or 6),

The ITS requires 4 DGs to be OPERABLE to support a unit in MODES 1-4 ( 2 unit specific DGs, the common DG, and one opposite unit DG). With the (0) DG inoperable, the ITS will continue to require a minimum of 3 DGs to be OPERABLE. This is consistent with the existing requirement: 1.e., no change.

4) the three remaining OPERABLE diesel generators shall be demonstrated OPERABLE by performance of Surveillance Requirement 4.15.1.B.2 within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months prior to removal of the common diesel (0) from service, The NRC staff has determined that anticipatory testing of DGs such as described in this CTS requirement is harmful to DGs and should not be required. Successful performance of routine surveillances provide adequate assurance of DG reliability without the need for extra testing. This is reflected in GL 93-05 (NUREG 1366), Rev. 3 to RG 1.9, and in the ITS (NUREGs 1430-1434). The Zion ITS will not include this CTS requirement, but will provide added assurance of remaining component OPERABILITY with the (0) DG inoperable through LC0 3.8.1 Required Actions B.3.1 and B.3.2, and through implementation of the Safety Function Determination Program.

5) prior to taking the common diesel generator (0) out of service, verify that at least three service water pumps and three component cooling water pumps are OPERABLE with their associated emergency power supplies, The CTS requires three component cooling water and three service water pumps to be operable for a single unit in Mode 1, 2, 3, or 4 with the opposite unit in Modes 5, or 6 .

Based on the ITS requiring four component cooling water and four service water pumps to be operable for the same condition, operation with one diesel generator inoperable I:\da ta\ziontsip\nrcser 2\ review 2\ attach _1 29 l

... J

Attachment 1 DOC Technical Review will still result in at least three pumps being available to function in the event of a design basis accident. This is consistent with the minimum required number of pumps for event mitigation. The Safety Function Determination Program, in conjunction with redundant component verifications contained with LCO 3.8.1 will preserve this minimum cumber of components required for event mitigation.

6) during the 7 day period, the three remaining OPERABLE diesel generators shall be verified OPERABLE daily, in addition to any testing required by Surveillance Requirement 4.15.1.B.2, Operability verification is an ongoing iterative process.

Based on CTS defining this verification as a administrative check, ongoing plant awareness of equipment configuration and status, which is a continuous process, fulfills this requirement. Therefore this specified action is a continuous )rocess and is an unnecessary level of detail for the Tecinical Specifications,

7) during the 7 day period, for the unit in MODE 5 or 6. no mid-loop or reduced RCS inventory operations, as defir.ed in NRC Generic Letter 88-17, will be performed while fuel is in the vessel, During mid-loop operation, Generic Letter 88-17 required plants to provide two alternate methods for adding inventory to the RCS, that are in addition to the normal decay heat removal systems-(GL 88-17, expeditious action 6). The Zion Station response stated that the two methods would be a high head injection pump and gravity feed from the refueling water storage tank (the normal method of decay heat removal is the Residual Heat Removal System).

The (0) DG does not provide power to either of the two alternate methods. Should one or more DGs (other than the (0) DG ) for the operating unit become in operable, the operating unit will be brought to MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 5 within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

8&9) Shutdown actions for additional equipment inoperabilities (service water, ECCS, diesel generators) are addressed within-the context of the Safety Function Determination program, redundant component operability verifications, and the conditions for addition diesel inoperabilities contained in LCO 3.8.1 and LCO 3.8.2.

1:\ data \ziontsip\nrcser2\ review 2\ attach _1 30

____.- J

- Attachment 1 DOC Technical Review-A detailed probabilistic assessment regarding the unrestricted 7 day A0T for the (0) DG has been performed at Zion. The results of this assessment support the above conclusions, particularly with respect-to deleting the CTS constraints tiat the 7 day A0T-be limited to those times when the (0) DG is inoperable for maintenance and one unit is-in MDDE 5 or 6.

Zion DOC L-10. 39. . The common diesel generator (0 DG) is shared between Unit 1 and Unit 2. The current Technical Specifications allow a 7-day _ outage time for an inoperable 0-DG on an operating unit only if:

a. The 0-DG is inoperable for maintenance or testing; and

b. The other unit is shutdown (MODE 5 or 6).

Otherwise, the allowed outage time (A0T) is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The 7-day A0T is necessary in order to avoid dual unit outages when performing required maintenance and testing on the 0-DG which typically takes longer than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . However, the revision is being made to allow the 7-day A0T for all 0-DG inoperabilities; eliminating the above two limitations. The following discussion shows that the resultant change in plant risk is acceptable. -

The current footnote "*" allows applying the 7 day limit only to testing and preplanned maintenance.- The revision will provide increased flexibility to use the 7 day allowance even after the .

0-DG has been determined to be inoperable for some other reason.

The Zion DG PRA analysis used to support the Comed application for

-the current Technical Specification-(WCAP-12873, dated February 1991, which was previously transmitted to the NRC in the letter from S. F. Stimac to T. E. Morley dated March 27,1991), showed

- that a 7-day A0T for the 0-Da was acceptable without the above-conditions. The justification was not dependent on why the diesel generator was incperable. Furthermore, any risk increase due to a DG outage is independent of the purpose of_the outage. In the discussion, below, that risk is shown to be acceptable.

Therefore, in the current proposal the 7 days is being provided for any reason the diesel is found to be inoperable.

39. (continued)

Furthermore, the 7-day limit is being proposed to apply to each unit, even with both units operating. Currently, an operating h\ data \ziontsip\nrcser2\ review 2\ attach _1 31.

_ _ _ _ - - .J

Attachment 1 l DOC Technical Review unit is only allowed the 7 day outage time if the other unit is already in MODE 5 or 6. In the amendment that added this 7 day allowance (letter from J. B. Hickman (NRC) to T. J. Kovach (CECO) dated May 17,1991) the justification used for the 7 day allowance was that the previous Technical Specifications allowed a 7 day time for all diesel generators and that a PRA (referenced above) was performed to justify maintaining the 7 day outage tinne for the 0-DG. That PRA had also reviewed the case of a 7 day limit with both units operating and had determined the core damage frequency, for Technical Specifications allowing the 7-day outage with both units operating, would be essentially the same as for a Technical Specification allowing the outage only with one unit operating and one unit shutdown. Although the projected average unavailability with the more liberal A0T conditions was slightly higher, this did not have a significant impact on the core damage frequency.

Therefore, based on that analysis, the proposed change has no adverse affect on safety and would provide appropriate time to repair an inoperable diesel generator prior to requiring shutdown of the units.

That 1991 PRA analysis was based on the 1981 Zion PRA, called the Zion Probabilistic Safety Analysis (ZPSS). Since that time, Comed hss completed the Zion IPE, which provides improved modeling of the plant and more recent equipment failure data. Furthermore, the 1991 analysis involved making projections (assumptions) of what the change in DG unavailability would be while operating under the proposed Technical Specifications. It is worth examining what conclusions would be drawn from the more recent-PRA, and whether conclusions can be formed which are independent of assumptions concerning actual out-of-service history. A useful way to approach this is to examine the risk increase of an outage of the 0-DG compared to the risk due to an outage of a unit DG, Those risks are different because different equipment is powr ed by the 0-DG, compared to the unit DG's. The 0-DG powers no RHR pamps and no AFW pumps. Consequently, it would not be surprising if the 0-DG turned out to be less important than the unit DG's.

A 72-hour A0T for a unit DG is an accepted part of standardized Technical Specifications. An A0T for the 0-DG that provides a comparable impact on core damage frequency should, therefore, also be acceptable. Because the Zion service water and component cooling water systems are shared between the units, an outage of a unit DG has an effect on both units. The primary effect is on that DG's unit; however, there is a small effect on the opposite unit due to the fact that one unit's service water and component cooling water pumps are "back-up's" for the other unit.

1:\d ata\ziont sip',nt e ser 2 \r eview 2 \a ttach_1 32

Attachment 1 DOC Technical Review According to the equipment outage risk evaluation tool OSPRE, which is based on the Zion IPE, the risk impact on the affected unit, during the time that a unit DG is out of service, is a core damage frequency increase of 1.41 x 10~'/yr. The effect on the opposite unit is a core damage frequency increase of 1.1 x 10'

/yr. The total effect on both units is a CDF increase of 1.52 x 10/yr. The risk impact of a 72-hour outage is therefore, (1.52 x 10/yr.) x (72 hr.) x (1 yr./8770 hr.) - 1.3 x 104.

For the 0-DG, the risk impact on one unit, during the time that a unit DG is out of service, is a core damage frequency increase of 3.6 x 10'/yr. The effect on two units is twice that, or 7.2 x 10/yr. The A0T, with a risk equivalent to that of a 72-hour unit DG A0T, is (1.3 x 104 ) / [(7.2 x 10'*/yr.) x (1 yr./365.25 days)] - 6.6 days or, rounding up, 7 days. Therefore, the Zion IPE shows that the total risk impact, with both units operating, of a 7-day outage of the 0-DG, is equivalent to the total risk impact of a 72-hour outage of either unit DG. Since the 72-hour A0T is acceptable, the 7-day A0T for the 0 DG, with both units operating, is acceptable. The Zion IPE confirms the conclusions of the earlier study that a 7-day A0T, regardless of cause, for the 0-DG, with both units operating is acceptable.

Comed has very recently modified the Zion IPE, in response to NRC review. While an OSPRE model based on that version is not yet available, it can be concluded, based on the dominant sequence listing, that the importance of the 0-DG is less than in the original Zion IPE, and, therefore, the risk of an 0-DG outage, as determined by the modified Zion IPE, would be even less than that determined by the original Zion IPE.

Given the above changes, the current administrative requirements required " prior to" causing the intentional inoperability for maintenance or testing, are also deleted. Since the 7 day allowance is being provided for any inoperability, verifications and demonstrations required " prior to" an unexpected inoperability are not possible. These deleted demonstrations were only to provide added assurance of remaining DG OPERABILITY (refer to discussion 3.8-40 related to the verification of SW and CC pumps),

which is adequately assured by routine Surveillances and the requirements proposed in LC0 3.8.1 Required Actions B.3.1 and 1:\ data \ziontsip\nrcser2\ review 2\ attach,1 33

l Attachment 1 DOC Technical Review s.3.2.

Finally, the requirement that during the 7-day A0T no mid-loop operation is allowed on the shutdown unit is being deleted.

During mid-loop operation, Generic Letter 88-17 required plants to provide two alternate methods for adding inventory to the RCS, that are in addition to the normal decay heat removal systems (GL 88-17, expeditious action 6). The Zion Station response stated that the two methods would be a high head injection pump and gravity feed from the refueling water storage tank (the normal method of decay heat removal is the Residual Heat Removal System).

The 0 DG does not provide power to either of the two alternate methods.

Therefore, allowing mid-loop operations (under the control of the shutdown units Technical Specification compliance) would have no adverse safety impact on a unit operating for 7 days with an inoperable 0-DG.

Discrepancy The NRC SER discussion of DOC 3.8-39 was enhanced in dialog between NRC and Comed subsequent to the submittal of DOC 3.8-39. The Zion DOC has been amended to address these enhancements and is included in Attachment 4.

NRC SER APPENDIX A

SUMMARY

OF RELOCATED ZION CURRENT TECHNICAL SPECIFICATIONS Discrepancy In column 1, row 3, CTS 4.2.1.D.2 is dasignated as relocated to Bases and COLR. However, this material has been relocated to plant procedures.

Therefore, reference to CTS 4.2.1.D.2 should be deleted from Appendix A to be consistent with the representation of other material relocated to procedures.

In column 1, row 33, CTS 4.13.ll.A is designated as relocated to the UFSAR.

However, this material has been relocated to plant procedures. Therefore, reference to CTS 4.13.11.A should be deleted from Appendix A to be consistent with the representation of other mtterial relocated to procedures.

1:\ data \ziontsip\nrcser2\ review 2\ attach _1 34

_ . . . . . .- J

Attachment 1 DOC Technical Review Zion Solit Report Page 4-1 of the Zion Split report stated that two license conditions were relocated to owner controlled documents and that two license conditions were relocated to Section 5.0 of the ITS. In reality, one license condition was relocated to owner control and three license conditions were moved to Section 5.0. In addition, the Split Report is unclear relative to what document will be used to control items relocated from the Technical Specifications using the screening criteria contained in 10 CFR 50.36. This point has been clarift*

providing reference to the UFSAR. Attachment 4 provides contains a revised page 4-1.

1:\ data \ziontsip\ntcser2\ review 2\ attach _1 35

____-__a

4 4

Attachment 2

- - - - - . _ _ _ _ _ _ _J

L

-Attachment 2 4 DOD Technical Review NRC SER D00 1.0 Use and Apo11 cation

3. Not used (This SE follows the format of the licensee's NUREG Differences submittal, Changes made during the submittal development sometimes resulted in a Discussion of Change (DOC) being deleted. Rather than renumbering the remaining DOCS and changing the associated NUREG markup, the affected DOC No, became NOT USED; i.e., there are no changes or discussions related to that number. This is consistent throughout this section of the SE.)

Zion D00

3. A portion of the definition for DOSE EQUIVALENT I-131 has been relocated to the Bases for Specification 3.4.16 "RCS Specific Activity" and Specification 3.7.18, Secondary Specific Activity. This change will make the content of the definition consistent with that of other definitions and permit future updates of the DOSE EQUIYALENT I-131 calculational methods that are used to determine the values for RCS and Secondary Specific Activity to be revised in accordance with the Technical Specification Bases Control Program. This change has been accepted by the Westinghouse Owners Group and is being tracked as WSTS-1 C.I.

Discrepancy In previous reviews the Zion change to CTS was not accepted, therefore, the Zion D0D will be changed to #ot used. This change is contained in Attachment 4.

NRC SER D0D Section 3.3.5

5. A new SR (SR 3.3.5.2) is proposed for each of the functions associated with the LCO. An ACTUATION LOGIC TEST is required to verify the OPERABILITY of the logic circuitry associated with the devices. The LOP DG Start Instrumentation actuates on a two-out-of-three logic, Zion D0D

5. A new SR (SR 3.3.5.2) is proposed for each of the functions associated with the LCO. An ACTUATION LOGIC TEST is required to verify the OPERABILITY of the logic circuitry associated with the devices. The undervoltage devices associated with each bus require a two of two logic in order to develop a loss of voltage signal on the respective bus, t

1:\ data \rtontstp\nrcser2\ review 2\ attach _2 1

_. )

Att: chm:nt 2 DOD Tcchnic:1 Rovi3w Discrenaggy l The logic for the LOP DG start is actually two of two, correct NRC SER to read two of two logic.

NRC SER D0D 3.3.8 FHBE?s Actuation Instrumentation

1. LC0 3.3.8:

The FHBEFS is a single train system and is required to be "in operation" under certain conditions. Several changes were made to the Actions to

, reflect the single train system's multiple modes of o)eration, and to maintain current surveillance practices. The Applica)ility is also amended to reflect the plant specific licensing basis that requires the FHBEFS during movement of irradiated fuel assemblies in containment with the equipment hatch not intact, and during CORE ALTERATIONS.

Zion D00

1. LC0 3.3.8:

The FHBEFS is a single train system and is required to be "in operation" under certain conditions. Several changes were made to the Actions to reflect the single train system's multiple modes of caeration, and to maintain current surveillance practices. TheApplicabilityisalso amended to reflect plant specific licensing basis that requires the FHBEFS during movement of irradiated fuel assemblies in enntainment with the equipment hatch not intact.

Discrepancy Zion D00 does not include a statement regarding core alterations. The following will be added to the Zion D00: "and during CORE ALTERATIONS with the equipment hatch not intact." The NRC SER should be similarly revised to include the full MODE requirement. The proposed revision to this D00 is contained in Attachment 4.

HRC SER D00 3.6 Containment Systems

19. References to Appendix J have been changed to the Containmer.t Leakage Rate Testing Program following implementation of 10 CFR Part 50, Appendix J, Option B.

Zion D00

19. Deletei Discrepancy The wording in the NRC SER will be inserted in Zion D00; proposed changes to the D00 are contained in Attachment 4.

1:\ data \zlontsip\nrcser2\ review 2\ attach _2 2

Attcchment 2 DOD Tcchnical Ravi3w

19. References to Appendix J have been changed to the Containment Leakage Rats Testing Program following implementation of 10 CFR Part 50 Appendix J. Option B.

NRC SER D00 3.7 Plant Systems

14. NUREG-1431 LCO 3,7.10; Proposed LCO 3.7.9:

NUREG-1431 LCO 3.7.12; Proposed LCO 3.7.12:

NUREG-1431 LC0 3.7.131 Proposed LC0 3.7.13:

NUREG-1431 LCO 3.7.14; Proposed LCO 3.7.11:

The Control Room Emergency Filtration System (CREFS), Pipe Tunnel Emergency Filtration System (PTEFS), Emergency Core Cooling System (ECCS) & Containment Spray (CS) Cubicle Emergency Filtration System (CEFS), and Fuel Handling Building Emergency Filtration System (FHBEFS) have only one mode of operation. This mode is the " emergency mode" or

" post accident mode" and does not need to be described as such.

Therefore, all references to the type of mode which seem to indicate that the system has more than one operating mode are eliminated. This is reflected in SR 3.7.9.4, SR 3.7.11.4, SR 3.7.12.3, and SR 3.7.13.5.

Zion D0D

14. NUREG LC0 3.7.10; Proposed LC0 3.7.9:

NUREG LCO 3.7.12; Proposed LC0 3.7.12:

NUREG LCO 3.7.14; Proposed LC0 3.7.11:

The CREFS, PTEFS, and ECCS & CS CEFS have only one mode of operation.

This mode is the " emergency mode" or " post accident mode" and does not need to be described as such. Therefore, all references to the type of mode which seem to indicate that the system has more than one operating mode are eliminated. This is reflected in SR 3.7.9.4, SR 3.7.11.4, and SR 3.7.12.3.

DiscreD&nCY Zion D00 3.7-14 does not apply to LCO 3.7.13. Fuel Handling Building Ventilation System does have a normal and emergency mode of operation. The NRC SER should be corrected to match the Zion D00.

NRC SER 000 3.7 Plant Systems

40. Missing Zion D0D

40. Additional details concerning Zion-specific MSSV orifice size and asscciated steam flow rates are provided in the BASES for LC0 3.7.1, Main Steam Safety Valves (MSSVs).

DiscreDanCY The Zion D00 describes relocation of details which do not exist in NUREG 1431.

Accordingly, this D00 has been revised to be "Not Used". The revised D00 is 1:\ data \ziontsip\nrcser2\ review 2\ attach 2 3 j

_ _ _ _ i

Attachm:nt 2 DOD Tcchnic:1 Ravi3w L

contained in Attachment 4.

NRC SER 000 3.8 Electrical Power Systems

7. NOT USED Zion D0D

7. NUREG SR 3.8.1.2, Note 1 - This note is-not included since it is inconsistent with the remainder of the NUREG. Any test which satisfies the requirements of another test may be credited to satisfy both. This is standard practice and fully satisfies the requirements without specific identification. Further, a specific note here would present confusion for other testing which does not contain the note.

Discrepancy Include Zion D00 in the NRC SER.

NRC SER 000 3.8 Electrical Power Systems

16. NOT USED Zion D00

16. NUREG SR 3.8.1.8, Note 2, & SR 3.8.1.9, Note 2, & SR 3.8.1.10, Note 2, &

SR 3.8.1.11, Note 3, & SR 3.8.1.14, Note 3, & SR 3.8.1.16, Note 2, &

SR 3.8.1.17, Note 2, & SR 3.8.1.18, Note 2, & SR 3.8.1.19, Note 3, &

SR 3.8.4.6, Note 2, & SR 3.8.4.7, Note 3, & SR 3.8.4.8, Note 2 - This note is not included (and not combined with its preceding Note per generic change BWOG-05) since it is inconsistent with the remainder of the NUREG. Any occurrence of conditions which satisfy the requirement <

of a test may be credited'to satisfy the test, provided the appropriate documentation is available. This is standard practice and fully satisfies the requirements without specific identification. Further, a specific note here would present potential confusion for other testing which does not contain the note.

Discrepancy Include Zion D00 in the NRC SER.

D .

NRC SER D00 3.8 Electrical Power Systens

24. NUREG-1431 SR 3.8.1.11, SR 3.8.1.19, SR 3.8.1.20 - The NUREG-1431 use of "from standby conditions" is modified for plant specific design and terminology. Since the DG is expected to be able to start from both conditions, there is no need to specify "from standby conditions" in any SR except the 18 month " LOOP /LOCA" test. The standby conditions for 1 : \ data \z i ont s i p\nrcse r2\revi ew2\a t tach _2 4

. J

Attachment 2 DOD Tcchnic:l R .vi3w

(

this test have been further described as " normal" standby conditions, which are identified in the Bases, to assure the test begins from ambient conditions.

Zion D00

24. NUREG SR 3.8.1.11, SR 3.8.1.19 SR 3.8.1.20 - The NUREG use of "from standby conditions" is modified for plant specific design and terminology. Since the DG is expected to be able to start from both conditions, there is no need to specify "from standby conditions" in any SR except the 31 day,184 day and 18 month " LOOP /LOCA" test. The standby conditions for this test have been further described as " normal" standby conditions, which are identified in the Bases, to assure the test begins from ambient conditions.

Discrepancy The reference to 31 and 184 days should be added to NRC SER since any DG testing is actually started from standby conditions. In addition, the D0D states that the DG is expected to start from both conditions when in reality the DG is expected to be capable of starting from any condition. Accordingly this D00 has been changed to state any condition, and is included in Attachment 4.

lRC SER D00 3.9 Refuelino Goerations

30. Missing Zion D00

30. Additional information concerning minimum refueling cavity water level requirements when latching or unlatching control rod drive shafts-is provided.

DiscreDanCY Add Zion D00 to NRC SER.

1:\ data \ziontstp\nrcser2\ review 2\ attach _2 5

r Attachment 3

Attachment 3 DOC Neaders NRC SER DOC 3.1 Reactivity Control CTS 3.2.1.B.1 A. 5.

Zion DOC CTS 3.2.1.B A. 5.

Discrenancy Change NRC SER 3.2.1.B.1 to match Zion DOC 3.2.1.B NRC_5ER DOC 3.1 Reactivity Control CTS 3.2.3.C. Action A. 24.

Zion DOC CTS 3.2.1.C.1, 4.2.1.C.1, and 3.2.3.C Action A. 24.

Discrepiqql Change NRC SER to add 3.2.1.C.1, 4.2.1.C.1 NRC SER DOC 3.2 Power Distribution Limits CTS 3.2.2.A.4.4, 3.3.2.B.1, and 3.3.2.B.3 A. 13.

Zion DOC CTS 3.2.2.A.4,E3.2.2.B.1, and 3.2.2.B.3 A. 13.

Discrepancy Change NRC SER 3.2.2.A.4.4 to match-Zion DOC 3.2.2.A.4 NRC SER DOC 3.2 Power Distribution Limits 1

Attachment 3-DOC Headers-CTS 3.2.2.C.2 and 4.2.2.C.2

A. 38.

Zion DOC CTS 3.2.2.C.2, 4.2.2.8.1, and 4.2.2.C.2 A.- 38.

Discrenanty Add 4.2.2.5.1 to NRC'SER

'RC SER DOC 3.3.1 RTS Instrumentation CTS 2.1.1.A. 2.1.1.B.1 through 4.a. 2.1.1.B.5.a. 2.1.1.B.6 through 8, 2.1.1.C.

-and 2.1.2

-A. 1.

Zion DOC

CTS 2.1.1 Note 1, 2.1.1 Note 2, 2.1.1.A.1, 2.1.1.A.2,-2.1.1.A 3, 2.1.1.B.1,

-2.1.1.B.2, 2.1.1.B.3, 2.1.1.B.4a, 2.1.1.B.5a, 2.1.1.B.6, 2.1.1.B.7, 2.1.1.B.8, 2.1.1.C.1, 2.1.1.C.2, 2.1.1.C.3, 2.1.1.C.4, 2.1.1.C 5, 2.1.1.C.6. 2.1.1.C.7, 2.1.1.C.8, 2.1.2.A, 2.1.2.A. 2.1.2.A.1, 2.1.2.A.2, 2.1.2.8, 2.1.2.B.1, 2.1.2.C.-and 2.1.2.D A. 1.

Ritcrepancy Add Note 1, #ete 2 to NRC SER-IRC SER DOC 3.3.1 RTS Instrumentation

-CTS 2.1.1.E.4.b, 2.1.1.E.5.b, 2.1.1.8.6, 2.1.2.8 Footnotes:t and it, Fig.

2.1-2 ht, and Table 3.1-1, 6A, 7A, and Footnotes v and w.

A. . 2.

Zion DOC CTS 2.1.1.B.4a Footnote *, 2.1.1.B.4a Figure 2.1-2, 2.1.1.B.4b, 2.1.1.B.4b Footnote **,-2.1.1.B.5a Footnote *, 2.1.1.B.5b,-2.1.1.B.5b Footnote

, 2.1.1.B.6 Footnote *, 2.1.1.B.6 Footnote **, 2.1.2.B.1 Footnote *,

2.1.2.B.2, 2.1.2.B.2 Footnote **; and 3.1.1 Table 3.1-1 Function 6a, Function 6a Note v, Function 6a Operator Action, Function 6a Setpoint, Function 6b Note 2

Attachment 3 l

DOC Neaders vv, Function 7a, Function 7a Note v, Function 7a Operator Action, function 7a Setpoint, and Function 7b Note vv A. 2.

Discrepancy Replace NRC SER references with Zion DOC CTS 2.1.1.8.4a footnote *, 2.1.1.8.4a Figure 2.1-2, 2.1.1.8.4b, 2.1.1.8.4h Footnote **, 2.1.1.8.Sa Footnote *,

2.1.1.8.5b, 2.1.1.8.5b Footnote **, 2.1.1.B.6 Footnote *, 2.1.1.8.6 Footnote

- , 2.1.2.8.1 Footnote *, 2.1.2.8.2, 2.1.2.8.2 Footnote **; and 3.1.1 Table 3.1-1 Function 6s, Function 6a Note v, Function 6a Operator Actlon, Function 6a Setpoint, function 6b Mote sv, Function 7a, Function 7a Note v, Function 7a Operator Action, Fur:ction 7a Setpoint, and Function 7b Note vr NRC SER DOC 3.3.2 ESFAS Instrumentation CTS Table 3.4-1 Item III.A.2 A. 28.

Zion DOC CTS 3.4 Table 3.4-1, Item III.A)2 A. 28.

Discrepancy Add reference Table 4.4-1 Ites III.A.2 to both the NRC SER and the Zion DOC HRC SER DOC 3.3.2 ESFAS Instrumentation CTS Table 3.4-1 Items V.2, V.3 A. 40.a.

Zion DOC CTS 3.4 Table 3.4-1, Item V.2 A. 40.a.

Discrepancy Delete Y.3 from NRC SER NRC SER DOC 3.3.2 ESFAS Instrumentation 3

Attachment 3 DOC Headers CTS Table 3.4-1 Item V.5 A. 43.

Zion DOC CTS 3.4 Table 3.4-1, Item V.5 A. 43.

Discrepancy Add reference Table 4.4-1 Item F.5 to NRC SER NRC SER DOC 3.3.3 (PAM) Instrumentation CTS 3.8.8.B Action 2 A. 7.

Zion D0Q CTS 3.8.8.B Action 2. and 3.8.9 Action Section A. 7.

Discrepancy Add 3.8.9 Action Section to NRC SER

NRC SER_QQG 3.3.6 Containment Ventilation Isolation Instrumentation CTS Table 3.14-1 Item 1.B A. 3.

Zion DOC CTS 3.14 Table 3.14-1, Items 1.B and 2.A.2 Minimum Channels Operable A. 3.

Discrepancy Add 2.A.2 to the NRC SER NRC SER DOC 3.3.7 (CREFS) Actuation Instrumentation CTS Table 4.14-1 Item H 4

Attachment 3 DOC Headers L A. 2.

Zion DOC CTS 4.14 Table 4.14-1. Items 2.H Source Check L A. 2.

Discrepancy Change NRC SER H to match Zion DOC 2.H NRC $ER DOC 3.3.7 (CREFS) Actuation Instrumentation CTS Table 3.14-1 Item H A. 4.

Zion DOC CTS 3.14 Table 3.14-1, Items 2.H Applicable Modes A. 4.

Discrepancy Change NRC SER H to match Zion DOC 2.H NRC SER DOC 3.3.8 (FHBEFS) Actuation Instrumentation CTS 3.13.2.A.2 and Tables 3.14-1 and 4.14-1, Item 1.A L-A.. 1.

Zion DOC CTS 3.14 Table 3.14-1 and 4.14 Table 4.14-1, Items 1. A.2 L-A. 1.

Discrepancy Delete reference 3.13.2.A.2 and from NRC SER NRC SER DOC 3.4 Reactor Coolant System CTS 3.3.2.G.I.c, 3.3.2.G.2, 3.3.2.G Actions a.2,b.2, and c.2, and 4.3.2.G.J.b A. 34 5

Attachment 3 DOC Headers Zion DOC CTS 3.3.2 G Actions A.2, B.2, and C.2; 3.3.2.G.I.c, 3.3.2.G.2, 4.3.2.G.1.c, and 4.3.2 G.3.6.2 A. 34.

Discrepancy Add reference 4.3.2.G.J.c to NRC SER and change NRC SER 4.3.2.G.1.6 to match Zion DOC 4.3.2.G 3.6.2 NRC SER DOC 3.5 (ECCS)

CTS 3.8.1.A and 3.8.2.A, and 3.8.3.A A. 2.

Zion DOC 3.8.1.A, 3.8.5.A, 3.8.2.A A. 2.

DiscreD8nCY Change NkC SER 3.8.3.A to match Zion DOC 3.8.5 A NRC SER M G 3.5 (ECCS)

CTS 3.8.1.F.2, Footnotes (pg. 167), 3.8.5.A.2.b, and Footnotes (pg. 174)

A. 13.

Zion DOC 3.8.1.F.1 N*, 3.8.1.F.2, 3.8.1.F.2 N**, 3.8.5.A.2.a M*, 3.8.5.A.2.b, 3.8.5.A.2.b N**

A. 13.

Discrepancy Add 3.8.1.F.2, 3.8.5.A.2.s M* to NRC SER NRC SER DOC 3.6 Containment Systems O

CTS 3.9.3 A. 35.

6

Attac!anent 3 00C Headers Zion DOC 3.9.3.A.1 #*1, Page 199A A. 35.

Discrepancy Change NRC SER 3.9.3 to match Zion DOC 3.9.3.A.1 #*1 NRC SER DOC 3.6 Containment Systems CTS 3.9.3 '

A. 36.

Zion DOC 3.9.3.A #*2 A. 36.

Discrepancy Change NRC SER 3.9.3 to match Zion DOC 3.9.3.A #*2 NRC SER DOC 3.6 Containment Systems CTS 3.9.6 L-A. 54.

Zion DOC 3.9.6.A L-A. 54.

Discrepanqy Change NRC SER 3.9.6 to match Zion DOC 3.9.6.A NRC SER DOC 3.6 Containment Systems CTS 3.9.6 L-A. 55.

7

l l Attachment 3 DOC Headers Zion DOC 3.9.6.A, 4.9.6.8 L-A. 55.

Discrepancy Add 4.9.6.8 to NRC SER and change NRC SER 3.9.6 to match Zion DOC 3.9.6.A NRC_$ER_ DOC 3.6 Containment Systems CTS 3.10.2 A. 76.

Z_ ion DOC 3.10.2 Act a.4 ,

A. 76. 4 Discrepancy Change NRC SER 3.10.2 to match Zion DOC 3.10.2 Act a.4 NRC $ER DOC ).7 Plant Systems CTS 3.7.1.C and 3.7.3.A.1 A. 4.

Zion DOC

\

3.7.1.C 3.7.3.A Act A.1

, A. 4.

Discrepancy Change NRC SER 3.7.3.A.1 to match Zion DOC 3.7.3.A Act A.1 NRC SER.. DOC 3.7 Plant Svilems CTS 3.7.2 Actions f and h A. 18.

Zion DOC 8

_ __ _]

l l

Attachment 3 DOC Headers 3.7.2. A Act f 3.7.2. A Act h, J.7.2. A #*

A. 18.

Discrenancy Add 3.7.2.A #* to NRC SER NRC SER DOC 3.7 Plant Systems CTS 3.7.3.A Action B A. 25.

Zion DOC 3.7.3.A Act B, 3.7.3.A Act 8 #*

A. 25.

E11crepancy Add Act 8 #* to NRC SER NRC SER DOC 3.7 Plant Systems CTS 3.13.2.A L A. 38.

Zion DOC 3.13.2.A, 3.13.2.A Act L-A. 38.

DiscreD&Qgy Add reference 3.13.2.A Act to the NRC SER NRC SER DOC 3.8 Electrical Systems CIS 3.15.2.A A. 32.

Zion DOC 3.15.2.A, 3.15.2.C, 3.15.2.C #*

A. 32.

9

Attachment 3 DOC Headers Discrenancy Add 3.16.2.C. 3.15.2.C #* to NRC SER NRC SER DOC 5.0 Administrative Controls CTS 4.0.5, 4.0.5.a. 4.0.5.b. 4.0.5.c, 4.3.1.B.5.c. 4.3.4 Table 4.3.b 2, 4.22.1, 4.22.2, 3.3.2.F.3, 3.3.2.G.D. 6.1.3, 6.2.2, 6.3, 6.5, 6.6.2, 6.6.3.B.a. 6.6.3.B.f, 6.6.3.B.h, 6.6.3.B.1, 6.7.a. and Fig. 6.1-1 L.A. 6.

Zion DOC 6.07, 4.0.05.b, 6.06.03.8.n, 4.22.lA.3, 6.06.03.B.1, 4.03.01.B.5, 6.06.03.B.h, 4.22.2, 4.0.05.c, 4.22.1A.1, 6.06.03.B.f. 3.03.02.F.3, 4.03.04.C, 4.0.05.a.

6.06.03.8.c, 6.05, 4.03 T4.03.B 2, 4.22.lA.2, 6.06.02.A. 6.03, 6.06.03.B.a.

4.03.04.A. 6.01.3, 4.22.lA.4, 6.01.3 F6.1-1 N1, 6.01.3 F6.1 1 SE/SF, 6.06.02.B 6.01.03 F6.1-1 NSO, 4.0.05, 3.03.02.G ACT D, L.A. 6.

011Gr.ARABC2 Add 6.06.03.8.n, 6.06.03.8.c, and 3.3.4 to NRC SER, change NRC SER 3.3.2 G.D.

6.2.2 to match Zion DOC 3.03.02.G ACT D, 6.06.02.A NRC SER DOC 5.0 Administrative Controls CTS 6.6.1.F.1 and 6.6.1.F.2 L-A. 17.

Zion DOC Page316(CTS 6.6.1.F.1)

L-A. 17.

DiscreDAnfX Delete and 6.6.1.F.2 from NRC SER NRC SER DOC 3.2 Power Distribution limits CTS 3.2.2.A.4.4 L4 14.

10

l Attachment 3 DOC Needert Zion DOC 3.2.2.A.4 L 4. 14.

Discrenancy Change NRC SER 3.2.2.A.4.4 to match Zion DOC 3.2.2.A.4 NRC.5ER DOC 3.2 Power Distribution limits CTS 3.2.2.A.4.5 L5 16.

Zion DOC 3.2.2.A.5.1 L-5. 16.

Discrenancy Change NRC SER 3.2.2.A.4.5 to match Zion DOC 3.2.2.A.S.1 NRC SER DOC 3.3.1 Reactor Trio, instrumentation CTS Table 4.1-1, Items 24, 25, 26, and 27 L1 52.

Zion QQG 4.1 T4.1-1 24,25,26,27 L-1. *52. Permissives Discrenancy Change NRC SER to delete 24 NRC SER DOC 3.3.3 (PAM) Instrumentation CTS 3.8.9 Action a L-3 4.a.

Zion DOC 11 o

Attachment 3 DOC Headers Page 184 L-3 4a.

Discrenancy Change NRC SER to #/A NRC.5ER DOC 3.3.5 loss of Power (LOP) Diesel Generator (DG) Start Instrumentation CTS Table 4.4-1, items 6 and 7 L 2- 3.

Zion DOC 3.4 T3.4 1 V.6 L-2 3.

Discrepancy Change NRC SER Table 4.41, Items 6 and / to match Zion DOC T3.4-1 V.6 NRC SER DOC 3.4 Reactor Coolant System CTS Table 3.14-1 and Table 4.14-1 L-13. 67.

Zion DOC 4.3.3.A.1, 4.14 T4.14 2A2b, 2A2e L-13. 67.

DIscrecancy Add 4.3.3.A.] to NRC-SER NRC_5ER.. DOC 3.8 Electrical Power Systems CTS 3.0.5.a 1.- l 1

- Zion DOC s

12

Attachment 3 DOC Headers 3,0.5 L1 1 Discrenancy Change the NRC SER 3.0.5.a to match Zion DOC J.0.5 NRC SER DOC 3.1 Reactivity Control Systems l

CTS 3.2.3.C

, M. 23.

Zion DOC 3.2.3.C. 4.2.J.C M. 23.

Discrepancy Reference to 4.2.3.C must be added to NRC SER header.

)RC_1ER DOC 3.1 Reactivity Control Systems CTS 3.2.3.B.2 and 3.2.3.B.4 M. 29.

Zion DOC 3.2.3.B.2. 3.2.3.B.4 M. 29.

Discrepancy Based on review of the ITS Database and the CTS markup the following reference must be added to the NRC SER J.2.3.8.5 NRC SER DOC 3.1 Reactivity Control Systems CTS 3.2.1.D.1 and 3.2.1.D.3.a M. 30.

Zion DOC 13

I f

Attachment 3 DOC Headers 3.2.1.D.1, 3.2.1.D.3, 3.2.1.E, 3.2.3.A.3 M. 30.

Discrenancy References 3.2.1.E 3.2.3.A.3 should be added to the NRC SER and the .a removed from reference 3.2.1.D.3.

NRC $ER DOC 3.1 Reactivity Control Systems CTS 3.2.1.D.3.a M. 31.

Zion DOC 3.2.1.0.1, 3.2.1.D.3, 3.2.1.E M. 31.

Discrepancy References 3.2.1.D.1 and 3.2.1.E should be added to the NRC SER. The .a should be removed from the NRC SER reference 3.2.1.D.3. Reference 3.2.3. A.3 needs to be added to both the NRC SER and the Zion DOC based on 1TS database and CIS markup review.

NRC $ER DOC 3.1 Reactivity Control Systems CTS 3.2.3A.]

M. 39.b Zion DOC 3.2.3.A.I.b M. 39.b Discrepangy Correct the NRC SER to match Zion DOC 3.2.3.A.J.b. t NRC $ER DOC 3.1 Reactivity Control Systemi CTS 3.2.3.A.2 and 3.2.3.B.3 M. 41.

14

Attachment 3 DOC Headers Zion DOC 3.2.3.A.2, 3.2.3.B.1 M. 41.

Discrenancy Correct NRC SER reference 3.2.3.B.3 to match Zion DOC 3.2.3.B.1 NRC SER DOC 3.2 Powtr Distribution I,.131.t.1 CTS 3.2.2.A.1.1 M. 4.

Zion DOC 3.2.2.A.1.2 M. 4.

Discrenancy Correct NRC SER reference 3.2.2.A.I.1 to match Zion DOC 3.2.2.A.I.2 NRC SER DOC 3.2 Power Distribution Limits CTS 3.2.2.A.J.2, 3.2.2.A.2.2, 4.2.2A.J.2, and 4.2.2.A.2.2 M. 9b.

Zion DOC 3.2.2.A.2.1, 3.2.2.A.2.2, 4.2.2.A.2.1, 4.2.2.A.2.2 M. 9b.

Discrenancy NRC SER references CTS 3.2.2.A.J.2 and 4.2.2A.J 2 should be corrected to match the Zion DOC references 3.2.2.A.2.1 and 4.2.2.A.2.1 NRC_5ER_ DOC 3.2 Power Distribution Limits CTS N/A M. 12.

Zion DOC 15

Attachment 3 DOC Headers 3.2.2.A.1.1.3.2.2.A.1.2 M. 12.

Riifrenancy Change NRC SER reference from N/A to match Zion DOC J.2.2.A.J.1, 3.2.2.A.J.2 NRC SER DOC 3.2 Power Distribution limits CTS 4.2.2.A.6 M. 27.

Zion DOC 4.2.2.A.5 M. 27.

Discrepancy Correct NRC SER 4.2.2.A.6 to match Zion DOC 4.2.2.A.5 MRC SER DOC 3.3.1 Reactor Trio System CTS 3.3.2.C.I.b M. 56.

Zion DOC 3.2.2.C.l.b-M. 56.

Discrepancy Correct NRC SER reference 3.J.2.C.I.b to match Zion DOC 3.2.2.C.I.b NRC SER DOC 3.3.1 Reactor Trio System CTS Table 3.1-1 M. 58.

Zion DOC T3.1-1. T4.1-1 16 J

Attachment 3 DOC Headers M. 58.

Discrepancy Add reference T4.1-1 to NRC SER.

NRC.5ER DQG 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation CTS Tables 3.4-1 and 4.4-1, items V.6 and F.7 M. 3.

Zion DOC T3.4-1 V.6 M. 3.

Discrepancy Change NRC SER to delete and 4.4-1, and V.7 NRC SER DOC 3.4 Reactor Coolant System CTS 4.3.1.A.3 M. 10.

Zion DOC 4.3.1.A 3, 4.3.1.A.5 M. 10.

Discrepancy Add reference to NRC SER 4.3.1.A.5 to match Zion DOC.

NRC.5ER DOC 3.4 Reactor Coolant System CTS 3.3.1.0 and 4.3.1 M. 19.

Zion DOC Page 75 (3.3.1.0 and 4.3.1.0) 17

Attachment 3 l DOC Headers l

M. 19.

Discrepancy Change the NRC SER reference 4.3.1 to match the Zion DOC reference 4.3.1.0 NRC $ER DOC 3.4 Reactor Coolant System CTS 3.3.1 M. 21.

Zion DOC Page75(3.3.1.0) 0 M. 21.

Discrepancy Correct the NRC SER 3.3.1 to match the Zion DOC 3.3.1.D ,

NRC $ER DOC 3.4 Reactor Coolant System CTS 3.3.1 H. 23.

Zion DOC Page 75a(3.3.1.E)

M. 23.

DiSlCeD!DEX Correct the NRC SER 3.3.1 to match the Zion DOC 3.3.1.E NRC SER DOC 3.4 Reactor Coolant System CTS 3.3.1.F Action c M. 26.

Zion DOC 3.3.1.F Act 6,c,d M. 26.

18

Attachment 3 DOC Headers Discrenancy Change the NRC SER to include Actions b & d lRG_SER DOC 3.4 Reactor Coolant System CTS 4.3.2 s M. 30.

Zion DOC Page79(4.3.2.A)

M. 30.

Discrenancy Change the NRC SER 4.3.2 to match the Zion DOC 4.3.2.A llRC $ER DOC 3.4 Reactor Coolant System CTS 4.3.3 M. 50.

Zion DOC Page 95 (4.3.3.8)

M. 50.

Discrenancy Change the NRC SER 4.3.3 to match the Zion DOC 4.3.3.8 lBC_5H _DQC 3.5 Emeroency Core Coolina Systems (ECCS)

CTS 4.8.1, 4.8.2, and 4.8.3 H. 5.

Zion DOC Page 164 (4.8.1)

M. 5.

Discrepancy 19

l Attachment 3 DOC Headers Correct the NRC SER to delete the references 4.8.2, and 4.8.3 NRC_SULQQG 3.6 Containment Systems CTS 3.10.2.A M. 71.

Zion DOC 3.10.2.A Act a.1 M. 71.

Discrepancy Change NRC SER to reference Act a.1 NRC SER DOC 3.6 Containment Systems CTS 3.10.2 M. 77.

Zion DOC 3.10.2.A Act 6, Page 214b M. 77.

Discrepancy Change NRC SER 3.10.2 to match Zion DOC 3.10.2.A Act b NRC.5ER DOC L f_ Containment Systems CTS 3.10.3, 3.10.4, 3.10.5, and 3.10.6 M. 89.

Zion DOC 3.10.7 M. 89.

DiscreD1D$y Delete the references in the NRC SER and correct it to match the Zion DOC 20

Attachment 3 DOC Headers 3.10.7 NRC SER DOC 3.6 Containment Systems CTS 4.6.2.A M. 96.

Zion DOC CTS 3.6.2.A M. 96.

Discrepancy Change NRC SER 4.6.2.A to match Zion DOC 3.6.2.A NRC SER DOC 3.7 Plant Systems CTS 3.7.2.a, 3.7.2.b, 3.7.2.c, 3.7.2.d, 3.7.2.e, and 3.7.2.g M. 14.

Zion DOC 3.7.2.A Act a,b,d,e.g M. 14.

Discrepancy Change NRC SER 3.7.2.a, 3.7.2.b, 3.7.2.c, 3.7.2.d, 3.7.2.e, and 3.7.2.g to match Zion DOC 3.7.2.A Action a,6,d,e g NRC SER DOC 1 7 Plant Systems CTS 3.7.2.a, 3.7.2.b, 3.7.2.c, 3.7.2.d, 3.7.2.e, and 3.7.2.g i M. 15.

Zion DOC 3.7.2.A Act a,b,c,d,e.g; 3.7.3.A Act a.2.b M. 15.

Discrepancy Change NRC SER CTS 3.7.2.a, 3.7.2.b, 3.7.2.c, 3.7.2.d, 3.7.2.e, and 3.7.2.g to 21

_ a

Attachment 3 DOC Headers match Zion DOC 3.7.2.A Act a,6,c d.e.g; J.7.3.A Act a.2.6 NRC_5ER DOC 3.7 Plant Systems CTS 3.7.3 Action A.2.a M. 24.

Zion DOC 3.7.3.A Act a.2.a. 4.7.3.8 M. 24.

Discrenancy Add reference to NRC SER 4.7.3.8 NRC.5ER DOC 3.8 Electrical Power Systems CTS 4.15.2 M. 6.

Zion Q9G Page 257 (4.15.1.B.I.2)

M. 6.

Discrepancy Change NRC SER 4.15.2 to match the Zion DOC 4.15.1.8.1.2 NRC SER DOC 3.8 Electrical Power Systems CTS 4.15.1.B M. 10.

Zion DOC 4.15.1.B.2.a. Page 257 M. 10.

Discrepancy Change NRC SER 4.15.1.B to match Zion DOC 4.15.1.D.2.a 22

_ _ _ - - - - - - - - - - - - - - - - - - - - - - l

i l

Attachment 3 DOC Headers lutC SER DOC 3.8 Electrical Power Svsingi CTS 4.15.1.B.3.6 M. 15.

Zion. DOC 4.15.8.3.a M. 15.

Discrenancy Change NRC SER 4.15.1.B.3.6 to match Zion DOC 4.15.B.3.a NRC SER DOC 3.8 Electrical Power Systems CTS 4.15.1 M. 23.

Zion DOC Page260(4.15.1.D)

M. 23.

Discrenancy Change the NRC SER 4.15.1 to match the Zion DOC 4.15.1.0 NRC SER DOC 3.8 Electrical Power Systems CTS 3.15.2.A M. 42.

Zion DOC 3.15.2.C N*

M. 42.

Discrenancy Change NRC SER 3.15.2.A to match Zion DOC 3.15.2.C #*

NRC $ER DOC 3.8 Electrical Power Systems 23

Attachment 3 DOC Headers CTS 4.15.1.E.4.d M. 54.

Zion.D0C 4.15.1.E.4.d. 4.15.1.E.5, Page 262a, Page 263 M. 54.

Discrepancy Add reference 4.15.1.E.S to NRC SER.

MRC_5ER DOC 3.8 Electrical 'pwer Systems CTS 3.15.1.8, 3.15.2.C, and 3.15.2.D M. 56.

Zion DOC Page 265 (3.15.1.E 3.15.2.C, and 3.15.2.D)

M. 56.

Discrenancy Change NRC SER 3.15.1.8 to match Zion DOC 3.15.1.E i

24

Attachment 4 Attachment 4 is a summary listing of all identified DOC, DOD, and Application of the Selection Criteria changes identified during the review of the draft NRC SER, These changes have been incorporated into mark up and clean file pages located in Addendum 1 to this Attachment, a

ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report Zion DOC 1,4-01

'Ihe wording of the last sentence of Zion DOC 1.4 01 is being changed to be consistent with the wording of other DOCS for added information that was not previously addressed in the CFS. Proposed changes are as follows.

A. 1. Proposed Section 1.4 discusses the proper use and intcapretation of the Surveillance Frequency. The proposed section gives specific examples that will aid the user in understanding Surveillance Frequency. The revision is being proposed consistent with NUREG 1431.

Zion DOC 3.110 The current DOC is confusing and provides justification for the addition of a lower MTC limit which was added under DOC 3.151 Accordingly, DOC 3.1 10 has been changed as follows:

M. 10. The Moderator Temperature Coefficient (MTC) Specification Applicability for the upper limit has been changed from "Immediately prior to startup" to MODE I and MODE 2 with k,, 2: 1.0. The term "immediately" is vague and has been clarified by providing a specific Applicability. As a result, the change for the upper MTC limit is more prescriptive than the CTS applicability. This change is consistent with NUREG 1431.

Zion DOC 3.1-48 DOC 3.1-48 has been revised to discuss information concerning a specific method of performing the Surveillance Requirement being identified in plant procedures, consistent with NRC SER. Proposed changes are as follows.

L A. 48. The identification of a specific method to perform this surveillance has been moved to plant procedures. This information provides details of design or process which are not directly pertinent to the actual Surveillance Requirement, but rather describe an acceptable method of compliance.

L\ data \riontsip\ntract2\ review 2\ attach,s 1

ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report Since these details are not necessary to adequately describe the actual regulatory requirement, they can be moved to licensee controlled docurr.cnts without a significant impact on safety. Placing these details in controlled documents provides adequate assurance that they will be maintained. Changes to plant procedures will be controlled in accordance with Zion plant procedures change process. This change is consistent with NUREG 1431.

Zion DOC 3.2 29 The Zion DOC did not address the specific identification of the overhead alarm that was added to the Note to identify if an AFD monitor is in alarm. The DOC has been changed to the following:

A. 29. A Note has been added to proposed AFD SR 3.2.3.2 and SR 3.2.3.3 which clarify the use of the logged values. The Note indicates that AFD is considered to have been at the logged value for the duration of the preceding surveillance interval if the AFD values are not available. The values may still be available from computer logs even though the alarm is inoperable and should be utilized. This change is an administrative ,

clarification of the methodology only and is consistent with NUREG 1431.

Id~idditiSHTiiN6(ibisW6"addid thifspshif1salifidestifissihibisthsid annundstor windowsithat identifyJf aniAFD_ monitor is in alar;r@

Zion DOC 3.2 36 The Zion DO'; addresses the fact that the 12 hr frequency does not explicitly include that portion of the current frequency which requires such monitoring after any load change greater than 10%. The NRC SER should discuss the acceptability of the 12 hr frequency relative to monitoring QPTR after load changes. The Zion DOC has been modified to discuss this issue more clearly. The DOC should be changed to the followinE:

L 11, 36. CTS requirement 4.2.2.B.1.b has been revised as Suiveillance Requirement L\da ta\nontsip\n rese r2\ review 2\ attach) 2

ATTACHMiNT 4 Revised DOf' 3ODs,and Application of Selv tion Criteria Report (SR) 3.2.4.2, which is performed once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the OITR alarm is inoperable. OPTR may be determined by the use of excore power range channels, moveable incore detectors (SR 3.2.4.3), or core exit thermocouples (SR 3.2.4.4). Using this equipment will provice appropriate monimring of OITR limits when the unit is in operation. Reducing the frequency from four times per shift and following power changes in excess of 10% power is a less restrictive change.1-lowever, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is adequate to detect any relatively slow changes in OPTR, because for those cases of quadrant power tilt that occur quickly (e.g. a dropped rod),

there typically are other indications of abnormality that prompt a verification of core power tilt. This change is consistent with NUREG-1431.

Zion DOC 3.2 37 The term peaking factor limit describes the variable of concern in this Specification.

Accordingly, the term Safety Limit has been replaced with peaking factor limit in the Zion DOC.

1,12. 37. A Note is added to proposed SR 3.2.4.1 and SR 3.2.4.2 that allows three power range channels to be used for calculating OITR when one power range channel is inoperable, but only if TilERMAL POWER is below 75%

RTP. With an NIS power range channel inoperable, tilt monitoring for a portion of the reactor core becomes degraded. Large tilts are likely detected with the remaining channels before they are sufficient to result in exceeding a peaking factor limit from below 75% RTP, but the capability for detection of small power tilts (which may result in exceeding a peaking factor limit when above 75% RTP) in some quadrants is decreased.

Therefore, use of only three detectors is limited to < 75% RTP.

Zion DOC 3.3.119 DOC 3.3.1-19 provides a justification for changing the Mode of Applicability associated with the Intermediate Range Neutron Monitors. This DOC has been rewritten to clarify L\ data \riontsip\n rae r2\ review 2\a ttach,s 3

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ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report the change proposed. He DOC should be changed as follows:

19. Intermediate Range Neutron Flux L 1.

The Mode of Applicability for the Intermediate Range Neutron Monitors has been proposed to be above the P-6 setpoint and below the P 10 setpoint. This change is acceptable based on the following: With TilERMAL POWER below the P 6 setpoint, the source range instrumentation performs core monitoring and protective functions. The intermediate range instrumentation functions to provide core monitoring by providing overlap between the source range and power range neutron monitors. To support this function, the intermediate range monitors are proposed to be OPERABLE above the P 6 setpoint and below the power range instrumentation (10%). If between P-6 and P 10, and one required intermediate range channel becomes inoperable, an action has been provided to immediately suspend operations involving positive reactivity additions and to decrease power < P-6. This action places the unit in a condition where the source range instrumentation provides the required monitoring and protection and the intermediate range instrumentation is no longer required.

DOC 3.3.136 Both the Zion DOC 3.3.136 and the NRC SER discussion for 3.3.136 need to be changed to address the fact that the CTS requirement to verify shutdown margin if a source range channel is inoperable has been changed from "immediately" in CTS to "once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months " in ITS. This is a relaxation of the CTS requirement, and therefore the categorization of the Zion DOC needs to be changed from "A" to "L" L-1. 36. The Actions required by this Note, for the source range instrumentation, have been incorporated into the applicable Actions for this instrument Function. (DOC #18 for Source Range Neutron Flux). In addition, the requirement to immediately verify SDM has been changed to verify SDM once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Shutdown margin la required to be verified once every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in accordance with ITS SR 3.1.2.1 in Mode 5 which is also the Mode of Applicability for this Required Action. The source range I:\ data \nontsip\nruer2\ review 2\sttach,5 4 J

ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report monitors provide monitoring of core count rate which provides for direct monitoring of significant changes in reactivity. Prior to loss of monitoring capability, core conditions were being monitored for significant changes in reactivity. The loss of monitoring capability results in a need to increase the frequency of performing SDM verifications due to the loss of direct monitoring capability provW.ed by the source range monitor; however, immediately verificat!ua of SDM is unnecessary based on continuous monitoring capability being available up to the point when the source range monitor was lost. Additionally, the requirement to "immediately" verify SDM is vague and unbounding, therefore the addition of a specific Completion Time is a necessary change to bound completion of this action.

His change is consistent with NUREG 1431.

Zion DOC 3.3.8-07 Change DOC 3.3.8-07 to discuss administrative controls related to heavy loads. This discussion more accurately reflects the underlying basis for accepting the use of administrative controls when handling heavy loads over irradiated fuel.

L A. 7. The Applicability of this Specification has been modified to remove the requirement for system OPERABILITY during operation of the crane with heavy loads. System OPERABILITY during movement of heavy loads was required to cope with the consequences of dropping heavy loads on irradiated fuel, liowever, administrative controls are in place at Zion that preclude the movement of heavy loads over irradiated fuel. These administrative controls , consistent with NUREG-0612, " Control of IIcavy Imads at Nuclear Power Plants (7/80)," and are described in the UFSAR. Use of administrative controls for movement of heavy loads has been found acceptable by the staff as stated in GL 8511. GL 8511 concludes in part, that administrative controls are in place and are sufficient such that heavy loads considerations limits to the extent practicable the risks associated with handling heavy loads, and no additional licensing requirements are warranted. Based on the above, the staff concludes that the proposed change is acceptable. System L\ data \riontaip\nreser2\ review 2\ attach _s 5

ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report OPERABILITY will continue to be required during Core Alterations and during movement of irradiated fuel.

Zion DOC 3.4 71 DOC 3.4-71 has been changed to more accurately describe the operational benefit of the change. Proposed changes is as follows:

1 18, 71. CTS 4.3.2.G.1.a requires performance of a CilANNEL FUNCTIONAL TEST, excluding valve operation, on the PORV actuation channel within 31 days prior to entering a condition in which the PORV is required OPERABLE. This Specification creates unnecessary scheduling burdens and resource expenditures, and establishes the potential for missed surveillance during unplanned shutdowns. A Note has been added to the ITS to allow entry into the Mode of applicability for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to performing the surveillance. Without this note, the SR would have to be performed or verified performed even though the unit is not in the Mode of Applicability. This creates an unnecessary resource burden on the Station, and if not performed could lead to an increased potential for a missed smveillance, Technical Specification noncompliance, and delays in plant shutdown actions. This note will facilitate scheduling performance of the SR without impacting plant activities and reduce the potential for missed surveillances and delays in plant cooldown actions. This change is consistent with NUREG 1431.

Zion DOC 3,6_-L4 This DOC is categorized as an " Administrative" change, but this change reflects a more restrictive requirement. Accordingly, the classification has been changed to "M".

M. 14. In CTS 3.6.1.C, the number of fan coolers required to be OPERABLE has been increased from "four" to "five". The justification for this increase has been provided in discussion #1 of this attachment.

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ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report Zion DOC 3,7 38 His DOC requires a revision to specifically address the relocated information. Details concerning the requirement to place loads in a safe condition upon loss of fuel building exhaust ventilation system will be addressed by plant practices and procedures. The DOC should be changed to the following:

1 A. 38. De Applicability of this Specification has been modified to remove the need for system OPERABILITY during the operation of the crane with loads over irradiated fuel in the fuel building. This is based on the administrative controls to address the movement of any heavy load in the fuel handling building. In addition, the requirement to place loads in a safe condition is addressed by applicable plant practices and procedures.

This information provides details of design or process which are not directly pertinent to the actual requirements, i.e., Limiting Condition for Operation or Surveillance Requirement, which support the safety analysis but rather describe an acceptable method of compliance. These details will be moved to the UFSAR and appropriate procedurer. The controls also assure that the analyzed DBA is bounding for any potential accidents in the fuel handling building. Since these details are not necessary to adequately describe the actual regulatory requirement, they can be moved to licensee controlled documents without a impact on safety Placing these details in controlled documents provides adequate assurance that they will be malatained. Changes to these details will be controlled by 10 CFR 50.59. This change is consistent with NUREG 1431.

Zlor. DOC 3.8-39 Change DOC 3.8-39 to describe the reasons for the change without depending on PRA discussion. The rewritten DOC more accurately reflects what is being changed, and provides specific deterministic information supportive of the change. The proposed change is as follows:

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ATTACHMENT 4 Revised DOCS, DODs, and Applicatir n of Selection Criteria Report le10. 39. CTS Requirement:

He CTS requirement for a 7 day outage time for (0) or common DG under specific circumstances is being changed to allow a 7-day outage for the (0) DG at all times. The common diesel generator ((0) DG) is shared between Unit I and Unit 2. The current Technical Specifications allow a 7 dsy outage time for an inoperable (0) DG on an operating unit only under specific circumstances.

The 7 day AOT for the (0) DG is necessary in order to avoid dual unit outages when performing maintenance and testing on the (0) DG which typically takes longer than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Periodic maintenance is necessary to maintain an acceptable level of DG reliability. Maintenance and testing required for the DG typically requires a total time period of 14 days, based on recommendations provided by the diesel generator manufacturer, and Technical Specification Surveillance Requirements, in order to perform all the required work within the Technical Specification 7 day period, the work is segmented into multiple work periods. These are typically 7 days periods and are associated with refueling outages.

In the CTS the common DG may be taken out of service for up to seven days with one unit in Mode 1,2,3, or 4 providing the following limitations are met:

1) the common diesel generator is made inoperable for maintenance and testing

2) one unit is in MODE 5 or 6,

3) three remaining diesel generators are OPERABLE (two OPERABLE on the operating unit and one OPERABLE on the

, unit in MODE 5 or 6),

4) the three remaining OPERABLE diesel generators shall be demonstrated OPERABLE by performance of Surveillance Requirement 4.15.1.B.2 within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months prior to removal of the common diesel (O) from service, 1:\da ta\ tion tsip\n erse r2\revic= 2\ attach,5 8

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ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report

5) prior to taking the common diesel generaint (0) out of service, verify that at least three t.crvice water pumps and three component cooling water pumps are OPERABLE with their associated emergency power supplies.

6) during the 7 day period, the three remaining OPERABLE diesel generators shall be verified OPERABLE daily, in addition to any testing required by Surveillance Requirement 4.15.1.B.2,

7) during the 7 day period, for the unit in MODE 5 or 6, no mid loop or reduced RCS inventony operations, as defined in NRC Generic Letter 8817, will be performed while fuel is in the vessel,

8) in the event one or more diesel generators (other than the common diesel generator (O)) for the operating unit becomes inoperable, the operating unit will be brought to MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 5 within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , and

9) in the event two diesel generators (other than the common diesel generator (O)) on the unit in Mode 5 or 6 become inoperable, the operating unit will enter Actions 3.15.2.C and 3.0.5.

ITS Proposal:

The 7-day limit is being proposed to be independent of opposite unit operating condition, with the application restrictions deleted or addressed within the Technical Specification in a differing form as addressed below.

This change cannot in and of itself be considered separate of the changea implemented throughout the ITS. The ITS has addressed shared system interrelationship, requiring more equipment for operational and shutdown modes than the current Technical Specifications (CTS) require. That taken in conjunction with programs such as the Safety Function Determination Program, and heightened redundant component verification, will preserve the minimum number of systems and components necessary for event mitigation consistent with analysis assumptions. As addressed below, and taken in the aggregate, application of a 7 day restoration period for the common diesel generator, independent of the operational mode of a L\wta\tiontsip\nrcse r2\miew2\at tach,5 9 l

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ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report second unit, does not result in a decrease in overall plant safety.

1) The common diesel generator is made inoperable for maintenance and testing The current requirement allows applying the 7 da) !imit only to testing and preplanned maintenance. In the ITS proposal, the 7 days is being provided for any reason the diesel is found to be inoperable. The effect of an inoperable DG on overall plant safety is independent of the reason the DG is inoperable. Therefore, if it is acceptable for the (O) DG to be inoperable for 7 days for maintenance, it is acceptable for the DG to be inoperable for 7 days for any reason, Moreover, the only reason the (O) DG would be inoperable for extended periods (i.e.,7 days) would be for preventive or corrective maintenance. Since the CTS does not identify any specific type of maintenance, the CTS is effectively without meaning. The CTS constraint is, therefore, deleted. Systems required to be operable which are supported by the diesel generator will be evaluated in accordance with the Safety Function Detennination Program and redundant component verifications required by ITS LCO 3.8.1, thereby maintaining Technical Specifications required functions.

2) one unit is in MODE 5 or 6, The Service Water (SW) and Component Cooling (CC) systems are common to both units at Zion. Shared system interrelationships have been addressed in the ITS such that the minimum number of components necessary to mitigate an accident in one unit while supporting controlled shutdown or maintaining shutdown conditions on the opposite unit are preserved. The systems and components required to be operable in the FTS are consistent with the minimum required number of systems and components necessary for event mitigation. The safety function determination program, in conjunction with redundant component verifications contained with LCO 3.8.1 (which must be met for both units) wi'J preserve this minimum number of components required for event mitigation.

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ATTACHMENT 4 l Revised DOCS, DODs, and Application of Selection Criteria Report Therefore, operation under a limited duration is not affected by the operational mode of the other unit.

3) three remaining diesel generators are OPERABLE (two OPERABLE on the operating unit and one OPERABLE on the unit in MODE 5 or 6),

The ITS requires 4 DGs to be OPERABLE to support a unit in MODES 1-4 ( 2 unit specific DGs, the common DG, and one opposite unit DG). With the (O) DG inoperable, the ITS will continue to require a minimum of 3 DGs to be OPERABLE. This is consistent with the existing requirement: i.e., no change.

4) the three remaining OPERABLE diesel generators shall be demonstrated OPERABLE by performance of Surveillance Requirement 4.15.1.B.2 within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months prior to removal of the common diesel (O) from service, The NRC staff has determined that anticipatory testing of DGs such as described in this CIS requirement is harmful tu DGs and should not be required. Successful perfermance of routine surveillances provide adequate assurance of DG reliability without the need for extra testing. This is reflected in GL 93-05 (NUREG 1366), Rev. 3 to RG 1.9, and in the ITS (NUREGs 1430-1434). The Zion ITS will not include this CTS requirement, but will provide added assurance of remaining component OPERABILITY with the (O)

DG inoperable through LCO 3.8.1 Required Actions B.3.1 and B.3.2, and through implementation of the Safety Function Determination Program.

5) prior to taking the common diesel generator (O) out of service, verify that at least three service water pumps and three component cooling water pumps are OPERABLE with their associated emergency power supplies, The CTS requires three component cooling water and three service water pumps to be operable for a single unit in Mode 1,2,3, or 4 k\ data \ziontsip\nrcser2\ review 2\ attach _5 1}

ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report with the opposite unit in Modes 5, or 6. Based on the ITS requiring four component cooling water and four service water pumps to be operable for the same condition, operation with one diesel generator inoperable will still result in at least three pumps being available to function in the event of a design basis accident.

This is consistent with the minimum required number of pumps for event mitigation. The Safety Function Determination Program, in conjunction with redundant component verifications contained with LCO 3.8.1 will preserve this minimum number of components required for event mitigation.

6) during the 7 day period, the three remaining OPERABLE diesel generators shall be verified OPERABLE daily, in addition to any testing required by Surveillance Requirement 4.15.1.B.2, Operability verification is an ongoing iterative process. Based on CIS defining this verification as a administrative check, ongoing plant awareness of equiptr.ent confih uration and status, which is a continuous process, fulfills this requirement. Therefore this specified action is a continuous process and is an unnecessary level of detail for the Technical Specifications.

7) during the 7 day period, for the unit in MODE 5 or 6, no mid-loop or reduced RCS inventory operations, as defined in NRC Generic Leder 88-17, will be performed while fuel is in the vessel, During mid-loop operation, Generic Letter 88-17 required plants to provide two alternate methods for adding inventory to the RCS, that are in addition to the normal decay heat removal systems (GL 88-17, expeditious action 6). The Zion Station response stated that the two methods would be a high head injection pump and gravity feed from the refueling water storage tank (the normal method of t decay heat removal is the Residual Heat Removal System). The (0) DG does not provide power to either of the two alternate methods. Should one or more DGs (other than the (0) DG ) for the operating unit become in operable, the operating unit will be brought to MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and MODE 5 within the next h\ data \ziontsip\nrcser2\ review 2\ attach 5 12

ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

8&9) Shutdown actions for additional equipment inoperabilities (service water, ECCS, diesel generators) are addressed within the context of the Safety Function Determination program, redundant component operability verifications, and the conditions for additional diesel inoperabilities contained in LCO 3.8.1 and LCO 3.8.2.

A detailed probablistic assessment regarding the unrestricted 7 day AOT for the (O) DG has been performed at Zion. The results of this assessment support the above conclusions, particularly with respect to deleting the CTS constraints that the 7 day AOT be limited to those times when the (O) DG is inoperable for maintenance and one unit is in MODE S or 6.

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l ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report Zion DOD Section 1.0 03 In previous reviews the proposed Zion change to CTS DOSE EQUIVALENT I-131 definition was not accepted; therefore, the Zion DOD will be changed to Not Used.

Proposed change is as follows.

3. Not Used Zion DOD Section 3.3.8 01 Zion DOD 3.3.8-01 does not include a statement regarding CORE ALTERATIONS. In addition, neither the NRC SER nor the Zion DOD contain the complete applicability statement for this requirtement. Accordingly, the phrase " CORE ALTERATIONS with the equipment hatch not intact" has been added to the DOD. The proposed change is as follows.

1. LCO 3.3.8:

The FHBEFS is a single train system and is required to be "in operation" under certain conditions. Several changes were made to the Actions to reflect the single train system's multiple modes of operation, and to maintain current surveillance practices. The Applicability is also amended to reflect plant specific licensing basis that requires the FHBEFS during movement of irradiated fuel assemblies in containment with the equipment hatch not intact and during CORE ALTERATIONS with the equipment hatch not intact.

Zion DOD Section 3.619 The implementation of 10 CFR 50 Appendix J, Option B, was not addressed by the wording in DOD 3.6-19. The NRC discussion for this difference will be inserted in Zion DOD 3.6-19. Proposed changes are as follows.

19. References to Appendix J have been changed to the Containment Leakage Rate Testing Program following implementation of 10 CFR Part 50, Appendix J, Option B.

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ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report Zion DOD 3.7 40 The Zion DOD describes relocation of details which do not exist in NUREG 1431.

Accordingly, this DOD has been revised to be "Not Used". The revised DOD is as follows:

40. Not Used.

Zion DOD 3.8-24 The DOD states that the DG is expected to start from "both conditions" when in reality the DG is expected to be capable of starting from any condition. Accordingly this DOD has been changed to state any condition as shown below.

j 24. NUREG SR 3.8.1.11, SR 3.8.1.19, SR 3.8.1.20 - The NUREG use of "from standby conditions"is modified for plant specific design and terminology. Since the DG is expected to be able to start from any condition, there is no need to specify "from standby conditions" in any SR except the 31 day,184 day and 18 month " LOOP /LOCA" test. The standby conditions for this test have been further described as " normal" standby conditions, which are identified in the Bases, to assure the test begins from ambient conditions.

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ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report -

Zion Sollt Renort Page 4-1 of the Zion Split report stated that two license conditions were relocated to owner controlled documents and that two license conditions were relocated to Section 5.0 of the ITS. In reality, one license condition was relocated to owner control and three license conditions were moved to Section 5.0. In addition, the Split Report is unclear relative to what document will be used to control items relocated from the Technical Specifications using the screening criteria contained in 10CFR 50.36. This point has been clarified providing reference to the UFSAR. The revised page is as follows:

4. RESULTS OF APPLICATION OF SELECTION CRITERIA The selection criteria from Section 2 were applied to the Zion Technical Specifications.

The following Summary Disposition Matrix is a summary of that application indicating which Specifications are being retained or relocated, the criteria for inclusion, if applicable, the NRC results of the criteria application as expressed in the NRC Staff Review of NSSS Vendor Owners Groups Application of The Commission's Interim Policy Statement Criieria To Standard Technical Specifications, Wilgus/Murley letter dated May 9,1988, and any necessary explanatory notes. Discussions that document the rationale for the relocation of each Specification which failed to meet the selection criteria are provided in Appendix A, except as noted in the Summary Disposition Matrix.

In addition, Appendix B includes a summary of the evaluations performed for those Zion specific Technical Specifications not evaluated in WCAP-11618. Finally, five License Conditions were evaluated using the selection criteria for inclusion in the proposed Technical Specifications. The results of this evaluation concluded that one of the five License Conditions would be relocated to the UFSAR, three conditions are included in proposed Chapter 5.0, Administrative Controls, and one condition has been retained in proposed Technical Specification Section 3.4, Reactor Coolant System.

In addition to the Summary Disposition Matrix, two LCO cross reference Tables and one Table summarizing the relocated specifications are provided. Table 1 compares the Improved Standard Technical Specifications of NUREG-1431 to the proposed Zion Improved Technical Specifications, and will assist the reader in identifying the differences. Table 2 compares the Improved Standard Technical Specificatiora of NUREG-1431 to the current Zion Technical Specifications that meet the Policy

(

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t ATTACHMENT 4 Revised DOCS, DODs, and Application of Selection Criteria Report Statement Criteria and Table 3 lists the current Zion Technical Specifications that are proposed for relocation. Tables 2 and 3 are provided to assist the reader in assessing the changes to the current Zion Technical Specifications and their relationship to NUREG-1431.

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I Addendum 1 to Attachment 4 Mark Up and Clean Copy of DOC, DOD and Application of Selection Criteria Changes

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ML20211A912

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