ML20238C173

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Proposed Tech Specs Revising Trip Setpoint for Refueling Floor Radiation Monitors & Authorization Level for Approving Changes to Plant Operating Procedures Under Tech Spec Section 6.2
ML20238C173
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 12/22/1987
From:
COMMONWEALTH EDISON CO.
To:
Shared Package
ML20238C170 List:
References
3708K, NUDOCS 8712300100
Download: ML20238C173 (10)
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Text

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ATTACHMENT 1 EROPOSED CHANGES TO APPENDIX A

_ TECHNICAL SPECIFICATIONS FOR OUAD CITIES STATION UNITS 1 AND 2 FACILITY OPERATING LICENSES DPR-29 AND DPR-30

_ Revised Pages: 6.2-1 (DPR-29) 6.2-1 (DPR-30) 3.2/4.2-2 (DPR-29) 3.2/4.2-7 (DPR-29) 3.2/4.2-2 (DPR-30) 3.2/4.2-7 (DPR-30) 3708K l

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8712300100 871222 >

PDR ADOCK 05000254 P DCD '

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Qua0-CITIEF DPR 429 6.2 PLANT OPERATING PROCEDURES A, Detailed written procedures, including applicable checkoff lists co"ering items listed below shall be prepared, approved, and adhered to:

1. Normal startup, operation, and shutdown of the reactor, and other systems and' components involving nuclear safety of the facility.
2. Refueling operations.
3. Actions to be taken to correct specific and forseen potential malfunctions of systems or components, including responses to alarms, suspected primary system leaks. and abnormal radioactivity changes.
4. Emergency conditions involving potential or actual release of radioactivity ' Generating Station Emergency Plan" and station emergency and abnormal procedures.
5. Instrumentation operation which could have an effect on the safety of the facility.
6. Preventive and corrective maintenance operations which could have  ;

an affect on the safety of the facility.

7. Surveillance and testing requirements.
8. Tests and experiments.
9. Procedure to ensure safe shutdown of the plant
10. Station Security Plan and implementation procedures.
11. Fire Protection Program implementation.
12. 00CM implementation.
13. PCP implementation.

14 Working hours of the Shift Engineer Station Control Room Engineer, Shift Foreman and the Nuclear Station Operator job classifications such that the heavy use of overtime is not routinely required.

B. Radiation control procedures shall be maintained, made available to all station personnel, and adhered to. The procedures shall show permissible radiation exposure and shall be consistent with the requirements of 10 CFR 20. This radiation protection program shall be organized to meet the requirements of 10 CFR 20.

C. 1. Procedures for items identified in Specification 6.2.A and 6.2.B and any changes to such procedures shall be reviewed and approved by the Technical Staff Supervisor, the Assistant Superintendent.

and department head responsible for the activity performed. At least one person approving each of the above procedures shall hold a valid senior operator's license. In addition, these procedures

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and changes thereto must have authorization by a Station Superintendent before being implemented.

2. Work and instruction type procedures which implement approved maintenance or modification procedures shall be approved and authorized by the Asst. Supt. Maintenance where the writtenThe authority has been provided by a Station Superintendent.

" Maintenance Modification Procedure" utilized for safety related work shall be 50 approved only if procedures referenced in the

" Maintenance Modification Procedure " have been approved as required by 6.2.A. Procedures which do not fall within the requirement of 6.2.A or 6.2.B may be approved by the Department Heads.

D. Temporary changes to procedures 6.2.A and C.2.B above may be made provided:

1. The intent of the original procedure is not altered.
2. The change is approved by two members of the plant management staff. at least one of wnom holds a Senior Reactor Operator's license on the unit affected.

Awenoment No.

07268 6.2-1

OUAD-CIVfES DPR-30

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6.2 PLANT OPERATING PROCEDURES A. Detailed written procedures, including applicable checkoff. lists covering iten 3 listed below sna11 be prepared, approved. and adhered to:

1. Nornal startup, operation, and shutdown of the reactor, and other systems and* components involving nuclear safety of the facility.
2. Refueling operations.
3. Actions to be taken to correct specific and forseen potential malfunctions of systems or components, including responses to alarms, suspected primary system leaks, and abnormal radioactivity changes.
4. Emergency conditions involving potential or actual release of-radioactivity " Generating Station Emergency Plan" and station emergency and abnormal procedures.

5 Instrumentation operation which could have an effect on the safety of the facility.

6, Preventive and corrective maintenance operations which could have an affect on the safety of the facility.

7. Surveillance and testing requirements.
8. Tests and experiments.
9. Procedure to ensure safe shutdown of the plant
10. Station Security Plan and implementation procedures.
11. Fire Protection Program implementation.
12. 00CM implementation.
13. PCP implementation.

la. Working hours of the Shift Engineer. Station Control Room Engineer. Shif t Foreman and the Nuclear Station Operator job classifications such that the heavy use of overtime is not routinely required.

B. Radiation control procedures shall be maintained, made available to all station personnel, and adhered to. The procedures shall show permissible radiation exposure and snall be consistent with the requirements of 10 CFR 20. This radiation protection program shall be organized to meet the requirements of 10 CFR 20.

C. 1. Procedures for items identified in Specification 6.2. A and 6.2.B and any changes to such procedures shall be reviewed and approved by the Technical Staff Supervisor, the Assistant Superintendent, At and department head responsible for the activity performed.

least one person approving each of the above procedures shall hold a valid senior operator's license. In addition. these procedures and changes thereto must have authorization by a Station Superintendent before being implemented.

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2. Work and instruction type procedures which implement approved  !

maintenance or modification procedures shall be approved and j authorized by the Asst. Supt. Maintenance where the writtenThe authority has been provided by a Station Superintendent.

  • Maintenance Modification Procedure
  • utilized for safety related ,

work shall be so approved only if procedures referenced in the  !

  • Maintenance Modification Procedure
  • have been approved as required by 6.2.A. Procedures which do not fall within the requirement of 6.2.A or 6.2.B may be approved by the Department Heads.

D. Temporary changes to procedures 6.2. A and 6.2.B above may be made provided:

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1. The intent of the original procedure is not altered. l
2. The change is approved by two members of the plant management staf f. at least one of whom holds a Senior Reactor Operator's license on the unit affected. l j

6,2-1 Amendment No.

0726B f

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QUAD-CITIES DPR t D. Refueling Floor Radiation Monitors 0. Refueling Floor Radiation Monitors

1. Except as specified in Specift- The two refueling floor radiation cation 3.2.D.2, the two refuel- monitors shall be functionally tested ing floor radiation nonitors and calibrated as indicated in Table shall be operable whenever irra- 4.2-1. Reactor building ventilation diated fuel or components are isolation and standby gas treatment present in the fuel storage pool system initiation shall be performed and during refueling or fuel at least each operating cycle, movement operations.
2. One of the two refueling floor radiation monitors may be inop-erable for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If the inoperable monitor is not re-stored to service in this time, the reactor building ventilation system shall be isolated and the standby gas treatment operated untti repairs are complete.
3. The trip setting for the refuel-ing floor radiation mcnitors shall be set at a value of l 1 100 mR/hr.
4. Upon loss of both refueling floor radiation monitors while in use, the reactor building ventilation system shall be iso-lated and the standby gas treat-ment operated.

E. Postaccident Instrumentation E. Postaccident Instrumentation

.The limiting conditions for operation Postaccident instrumentation shall be for the instrumentation which is read functionally tested and calibrated as out in the control room, required for indicated in Table 4.2-2.

postaccident monitoring are given in Table 3.2-4.

i 3.2/4.2-2 Amendment No.

0723B

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QUAD-CITIES DPR-29 The APRM rod block function is flow biased and prevents a significant reduction in MCPR. especially during operation at reduced flow. The APRM provides gross core protection, i.e.. limits the gross withdrawal of control rods in the normal withdrawal sequence.

In the refuel and startup/ hot standby modes, the APRM rod block function is set at 12% of rated power. This control rod block provides the same type of protection in the Refuel and Startup/ Hot Standby modes as the APRM flow-biased rod block does in the Run mode. i.e.. prevents control rod withdrawal before a scram is reached.

The RBM rod block function provides local protection of the core i.e., the prevention of transition boiling in a local region of the core for a single rod withdrawal error from a limiting control rod pattern. The trip point is flow biased. The worst-case single control rod withdrawal error is analyzed for each reload to assure that, with the specific trip settings rod withdrawal is blocked before the MCPR reaches the fuel cladding integrity safety limit.

Below 30% power. the worst-case withdrawal of a single control rod without rod block action will not violate the fuel cladding integrity safety limit.

Thus the RBM rod block function is not required below this power level.

The IRM block function provides local as well as gross core protection. The scaling arrangement is such that the trip setting is less than a factor of 10 above the indicated level. Analysis of the worst-case accident results in rod block action before MCPR approaches the MCPR fuel cladding integrity safety limit.

A downscale indication on an APRM is an indication the instrument has failed or is not sensitive enough. In either case the instrument will not respond to changes in control rod motion, and the control rod motion is thus prevented. The downscale trips are set at 3/125 of full scale.

The SRM rod block with 1100 CPS and the detector not full inserted assures that the SRH's are not withdrawn from the core prior to commencing rod withdrawal for startup. The scram discharge volume high water level block provide annunciation fcr operator action. The alarm setpoint has been selected to provide adequate time to allow determination of the cause of level increase and corrective action prior to automatic scram initiation.

For effective emergency core cooling for small pipe breaks the HPCI system must function since reactor pressure does not decrease rapidly enough to allow either core spray or LPCI to operate in time. The automatic pressure relief function is provided as a backup to the HPCI in the event the HPCI does not operate. The arrangement of the tripping contacts is such as to provide this function when necessary and minimize spurious operation. The trip settings given in the specification are adequate to assure the above criteria are met (reference SAR Section 6.2 6.3). The specification preserves the effectiveness of the system during periods of reintenance, testing or calibration and also minimizes the risk of inadvertent operation, i.e. only one instrument channel out of service.

Two radiation monitors are provided on the refueling floor which initiate isolation of the reactor building and operation of the standby gas treatment l systems. The trip logic is one out of two. Trip settings of i 100 mR/hr l for the monitors on the refueling floor are based upon initiating normal ventilation isolation and standby gas treatment system operation 0723B 3.2/4.2-7 Amendment No.

~T

!j. a QUAD-CfTIES

- OPR-30 D. Refueling Floor Radiation Monitors 1.- Except as specified in Specift-cation 3.2.D.2, the two refuel-ing floor. radiation monttors-shall be_ operable whenever irra-diated fuel or components are present in the fuel storage pool and during refueling or fuel movement operations.

2. 'One of the two refueling floor radiation monitors may be inop- D. Refueling Floor Radiation Monitors erable for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If the The two refueling floor radiation inoperable monitor is not re- monitors shall be functionally tested stored to service in this time, the reactor building ventilation and calibrated as indicated in Table system shall be isolated and the 4.2-1. Reactor building ventilation standby gas treatment operated isolation and standby gas treatment until repairs are complete. system initiation shall be performed at least each operating cycle.
3. The trip setting for the refuel-ing floor radiation monitors shall be set at a value of l ,1 100 mR/hr.
4. Upon loss of both refueling floor-radiation monitors while in use, the reactor building ventilation system shall be iso-lated and.the standby gas treat-ment operated.

E. Postaccident Instrumentation E. Postaccident Instrumentation The-limiting conditions for operation Postaccident instrumentation shall be .

for the Instrumentation which is read functionally tested and calibrated as I out in the control room, required for indicated in Table 4.2-2.

s postaccident monitoring are given in Table 3.2 4.

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j 3.2/4.2-2 Amendment No.

0724B

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- QUAD-CITIES DPR-30 The APRM rod block function is flow biased and prevents a significant reduction in MCPR. especially during operation at reduced flow. The APRM provides gross core protection, i.e., limits the gross withdrawal of control rods in the normal withdrawal sequence.

In the refuel and startup/ hot standby modes, the APRM rod block function is set at 12% of rated power. This control rod block provides the same type of protection in the Refuc1 and Startup/ Hot $tandby modes as the APRM flow-biased rod block does in the Run mode, i.e.. prevents control rod withdrawal before a scram is reached.

The kBM rod block function provides local protection of the cc"P. i .e. . the prevention of transition boiling in a local region of the core for a single rod withdrawal error from a limiting control rod pattern. The trip point is flow biased. The worst-case single control rod withdrawal error is analyzed for each reload to assure that, with the specific trip settings rod withdrawal is blocked before the MCPR reaches the fuel cladding integrity safety limit.

Below 30% power, the worst-case withdrawal of a single Control rod without rod block action will not violate the fuel cladding integrity safety limit.

Thus the RBM rod block function is not required below this power level.

The IRM block function provices local as well as gross core protection. The scaling arrangement is such that the trip setting is less than a factor of 10 above the indicated level. Analysis of the worst-case accident results in rod block action before MCPR approaches the MCPR fuel cladding integrity safety limit.

A downsCale indication on an APRM is an indication the instrument has failed or is not sensitive enough. In either case the instrument will not respond to changes in control rod motion, and the control rod motion is thus prevented. The downscale trips are set at 3/125 of full scale.

The SRM rod block with 1 100 CPS and the detector not full inserted assures that the SRM's are not withdrawn from the core prior to commencing rod withdrawal for startup. The scram discharge volume high water level block provide annunciation for operator action. The alarm setpoint has been selected to provide adequate time to allow determination of the cause of level increase and corrective action prior to automatic scram initiation.

For effective emergency core cooling for small pipe breaks the HPCI system must function since reactor pressure does not decrease rapidly enough to allow either core spray or LPCI to operate in time. The automatic pressure relief function is provided as a backup to the HPCI in the event the HPCI does not operate. The arrangement of the tripping contacts is such as to provide this function when necessary and minimize spurious operation. The l

trip settings given in the specification are adequate to assure the above criteria are met (reference SAR Section 6.2.6.3). The specification preserves the effectiveness of the system during periods of maintenance, testing or calibration and also minimizes the risk of inadvertent operation. i 1.e. only one instrument channel out of service.

l Two radiation monitors are provided on the refueling floor which initiate l isolation of the reactor building and operation of the standby gas treatment l

systems. The trip logic is one out of two. Trip settings of i 100 mR/hr l for the monitors on the refueling floor are based upon initiating normal ventilation isolation and standby gas treatment system operation l

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0724B 3.2/4.2-7 Amenoment No.

-_ _ _ _ _ . ____________O

ATTACHMENT 2

SUMMARY

OF CHANGES Eight (8) changes to the Quad Cities Station Units 1 and 2 Technical Specifications have been identified and are listed below as follows:

1) Pages 3.2/4.2-2 (DPR-29) and 3.2/4.2-2 (DPR-30)

(a) Item D.3. - Insert " f;" sign following word "of" so the sentence reads "The trip setting for the refueling floor radiation monitors shall be set at a value of 6100mR/hr"

2) Pages 3.2/4.2-7 (DPR-29) and 3.2/4.2-7 (DPR-30)

(a) Last paragraph - Insert " 6." sign following word "of" so the sentence reads " Trip settings of6100mR/hr for the monitors..."

3) Pages 6.2-1 (DPR-29) and 6.2-1 (DPR-30)

(a) Item 6.2.C.1 - Replace " Specification 6.2-A" with: Specification 6.2.A and 6,2.B", so the sentence reads " Procedures for items identified in Specification 6.2.A and 6.2.B and any changes ...".

(b) Item 6.2.C.1 - Replace " Operating Engineer and the Technical Staff Supervisor in the areas of operation ... and the Radiation Chemistry Supervisor "with" Technical Staff Supervisor, the Assistant Superintendent, and department head responsible for the activity performed."

3984K l

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ATTACHMENT 3 l

EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION AND DESCRIPTION OF PROPOSED AMENDMENT REQUEST The proposed license amendment involves two items currently found in the Quad Cities Station Technical Specifications; the first establishes an upper bound limit for the refueling floor radiation monitors in lieu of the current parameter setpoint while the second upgrades the level of review for all procedure changes identified in Section 6.2.A and B to Assistant Superintendent level.

The current Technical Specifications for the refueling floor radiation monitors establishes a trip setpoint of 100mR/hr. The instruments are also calibrated at 100m R/hr which does not provide an allowance for normal instrument setpoint drift. To prevent inadvertent trips which may result from this situation, Commonwealth Edison has elected to change the trip setpoint from 100mR/hr to less than or equal to 100mR/hr.

The Section 6 Technical Specification change is administrative in nature. The highest level of authorization for operating procedure changes

- (per the current Tech Specs) is the Operating Engineer and Technical Staff Supervisor for operation and fuel handling activities, the Assistant Superintendent of Maintenance and Technical Staff Supervisor for maintenance and inspection activities and the Technical Staff and Radiation Chemistry Supervisors for procedure changes under Specification 6.2.B. The proposed change upgrades the level of review to the Assistant Superintendent level for all procedures identified in Section 6.2.A and 6.2.B of the Technical  ;

Specifications. This will result in a more uniform and consistent level of review for all areas of plant activities.

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

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

(a) the proposed amendment merely establishes an upper bound limit for the refuel floor radiation monitors consistent with what currently exists in the Tech Specs. This is considered to be a change in the conservative direction and therefore, does not result in an increase in the probability or consequences of previously evaluated accidents.

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(b) the proposed amendment revises the level of review to the Assistant Superintendent level for all procedures identified in Section 6.2.A and 6.2.B. of the Technical Specifications. This change results in a higher level of approval for changes to procedures than is currently provided in the Technical Specifications. This change is considered to be administrative in nature. Additionally, this change does not result in a negative impact on plant design or operation, hence the probability or consequences of previously evaluated accidents has not been adversely impacted.

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

(a) The proposed amendment does not change the actual setpoint for the refuel floor radlation monitors, but rather makes the 100mR/hr the upper bounding value. There are no hardware changes nor are there any new modes of operation associated with this amendment.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

(b) This is an administrative change. No new equipment or modes of operation have been introduced as a result of this change. Revising the authorization level for procedure changes to a higher level does not introduce any new equipment or modes of operation at Quad Cities Station that would create the possibility of a new or different kind of accident than that which was previously evaluated.

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

(a) We are not changing the setpoint from 100mR/hr to a different value, but rather are making this the upper bounding value for the refuel floor radiation monitors. This will prevent inadvertent trips which j may occur because of normal instrument drift and unnecessary system challenges. Therefore, the margin of safety has been actually J increased as a result of this change.

(b) These section 6 changes are considered to be administrative in I nature. There are no changes being made to hardware in the manner that plant system are being operated as a result of this license amendment. Therefore, the margin of safety is not being compromised.

Therefore, since the proposed license amendment satisfies the criteria specified in 10 CFR 50.92, commonwealth Edison has datermined that a l l

no significant hazards consideration exist for these items. We further request their approval in accordance with the provisions of 10 CFR 50.91(a)(4).

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