ML20246N649

Application for Amends to Licenses DPR-29 & DPR-30,deleting cycle-specific Core Limit from Tech Specs,Per Generic Ltr 88-16

ML20246N649
Person / Time
Site:	Quad Cities
Issue date:	07/11/1989
From:	Silady J COMMONWEALTH EDISON CO.
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML20246N654	List: ML20246N649 ML20246N655 ML20247D307 ML20247D317
References
0188T, 188T, GL-88-16, NUDOCS 8907200013
Download: ML20246N649 (8)

Text

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v , / } Comm:nw:cith Edison

(f ( ' 4 72 West /. dams Street, Chicago, Illinois

\ ABdress Reply to: Post OTfEBoi77

\- _ Chicago, liknois 60690 - 0767 July 11, 1989 i

Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC' 20555

Subject:

Quad Cities Nuclear Power Station Units 1 and 2 Proposed Amendment to Remove Cycle-Specific Core Limits from the Technical Specifications NRC Doc.kat Nos. 50-254 and 50-265

Reference:

Generic Letter 88-16 dated October 4, 1988.

Dr. Murley:

Pursuant to 10 CFR 50.90, Commonwealth Edison proposes to amend the Technical Specifications (Appendix A) of Facility Operating Licenses DPR-29 and DPR-30 for Quad Cities Nuclear Power Station Units 1 and 2, respectively.

The proposed amendment deletes cycle-specific core limits from the Technical ,

Specifications consistent with the guidance in the referenced Generic Letter.

As suggested in the referenced Generic Letter, the values of the removed core limits will be contained in a Core Operating Limits Report, which is referenced in each of the respective Limiting Conditions for Operation.

Similar amendments have been previously approved for the Oconee and Brunswick plants. The Quad Cities changes ere described in Attachment 1 including a safety evaluation summary. The afte ,s. pages of the Technical Specifications are contained in Attachment 2.

The proposed changes have been reviewed and approved by both On-Site-and Off-Site Review in accordance with Commonwealth Edison procedures. We have reviewed these proposed amendments in accordance with 10 CFR 50 92(c) and determined that no significant hazards consideration exists. This evaluation is documented in Attachment 3.

Enclosed as Attachment 4 are examples of the Core Operating Limits Report for both units using data for the operating cycles currently in progress. As suggested in the Generic Letter and specified in the proposed Section 6 administrative requirement, CECO will provide these reports for each future Quad Cities reload beginning with Unit 1 Cycle 11 (Reload 10), which is currently scheduled to start in November, 1989. Whenever appropriate, the 8907200013 890711 PDR '

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. ,f; T.E. Murley July 11, 1989 reloads will be reviewed by CECO.per 10 CFR 50.59 in order to realize the full benefits of the Generic Letter 88 16 approach-including. reduced NRC resources' for reload reviews. Since the Unit 1 Cycle 11 reload utilizes NRC-approved fuel types, analytical methodologies, etc., CECO believes that 10 CFR 50.59 can be applied, provided this amendment is processed in a timely manner.

l Commonwealth Edison is notifying the State of Illinois of our l- opp 11 cation for this amendment by transmitting a copy of this letter and its l attachment to the designated State Official.

l' l Please direct any questions you may have regarding this matter to this l office.

Very truly yours, pa -

J. A. Silady.

Nuclear Licensing Administrator Im.

Attachments 1: Description of Proposed Changes and Safety Evaluation 2: Proposed Changes to Appendix A Technical Specifications for Quad cities Units 1 and 2 3: Significant Hazards Evaluation 4: Examples of Core Operating Limits Reports l

cc: A.B. Davis - Region Administrator, Region III ;l l

l- R.L. Higgins - Senior Resident Inspector, Quad Cities T.M. Ross - Project Manager - NRR D.R. Hoffman - Excel Services

. Office of Nuclear Facility Services - IDNS

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gg tJ / .1989 LELIA F. MAYO  :'

, Notary Public. State of Illinois.

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REMOVAL OF CYCLE SPEC 1ElC EONER_DJSIBIMI1ON LIMITS FROM QUAD CITIES STATION NUCLEAR POWER UNITS 1 AND 2 l

IECIMLCAL_EEECIFICATI0 tis l l

l IA E E__0E._CONTEMIS ATIACIRdERTISl IDEIC

1. Description of Proposed Changes and Safety Evaluation A. Background B. Description of Actions Necessary to Implement Generic Letter 88-16 C. Description of Technical Specification Changes D. Summary

2. Proposed Technical Specification Changes

3. Significant Hazards Evaluation

4. Example Core Operating Limits Reports (COLR) 0188T 3

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- ATIACUMENTJ DISCRIETIDN-.QI IRQfQSED_fJIAUGES AHD_SAEETY EVALUAIIDH The following safety evaluation describes the actions needed to be taken to remove the cycle-specific and bundle-specific thermal limits from the Quad Cities Nuclear Power Station, Units 1 and 2 Technical Specifications and place them in a new controlled document called the Core Operating Limits Heport. Completion of these actions will facilitate 10 CFR 50.59 reviews for future Quad Cities cycles. The safety evaluation is divided into the following sections:

A. Background B. Description of Actions Necessary to Implement Generic Letter 88-16 C. Description of Technical Specification Changes D. Safety Evaluation Summary A. DACKGBDUNJ1 Currently, the Quad Cities Nuclear Power Station, Units 1 and 2 Technical Specifications include cycle-specific and fuel bundle type specific power distribution operating limits. Typically, changes to these power distribution limits must be submitted prior to each refueling outage to reflect upcoming cycle-specific characteristics. Since these limits are determined using a methodology previously approved by the NRC, these frequent license amendments are an unnecessary burden on utility and NRC resources. In order to facilitate the elimination of these unnecessary amendments, the NRC has issued Generic Letter 88-16, " Removal of Cycle-Specific Parameter Limits From Technical Specifications". The Generic Letter provides guidance in removing the cycle-specific and bundle-specific operating limits from the plant Technical Specifications and creating a Core Operating Limits Report to put them in. Conanonwealth Edison has prepared changes to the Technical Specifications consistent with Generic Letter 88-16 and the previously approved lead BWR (Brunswick) amendment. This should allow the NRC to expedite review of the proposed Technical Specification amendment.

B. D E SC R I EIl ON_OLACTIDN S_N EEESEARLTD_.l MRL EMERLG EN ERIflETT E R_&M The proposed Technical Specification amendment removes the cycle-specific and fuel bundle type specific limits (Average Planar Linear Heat Generation Rate, Minimum Critical Power Ratio, Linear Heat Generation Rate, and Rod Block Monitor Upscale Setpoints). In place of these limits,

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/ .x iF s references.to the Core' Operating Limits Report (COLR) are added. .The COLR

'isla unit specific-document containing the power distribution limits that are' applicable for a: specific cycle. Commonwealth Edison will. continue to meet'~1ts: responsibility for. ensuring NRC approved analytical methods'are used for reload safety analyses and, per-this amendment, as the basis for.

the results reported in the COLR. An example of how theLCOLR would. appear .

' for. the present Quad Cities cycles (Unit 1 Cycle 10 and Unit 2 Cycle,10) is.provided in Attachment 4. The COLR for future operating cycles:will be submitted to the NRC for information prior to startup following each -

refueling. outage, as required by Generic Letter 88-16. The implementation rad revision of the COLRs will be controlled by.a new Administrative

' Procedure. It- should be noted that COLR revisions will receive the same 1evel.of detailed review and required approvals in the Nuclear Fuel Services (NFS) Department, On-Site Review and'Off-Site Review as Technical.

Specification changes. In addition, the Definitions section of the:

i Technical. Specifications shall have an entry entitled " Core Operating Limits. Report"'and there will be's new administrative reporting require-

• ment added to the existing reporting. requirements in.Section 6.6.A of the Technical Specifications.. The actual Quad Cities Technical Specification changes are addressed in Section C, " Description of Technical Specification Changes" Land Attachment 2.

Although th'si amendment proposes Technical Specification changes for both

-Quad Cities units, Commonwealth Edison intends to implement these changes as Cycle 11 operation begins at each individual unit. Quad Cities Unit 1 will use the same basic reload fuel type for the fresh fuel batch in Cycle 11ans was used in Cycle 10, i.e., the NRC-approved GE 8x8EB Fuel Design.

For Quad-Cities. Unit 2 the primary difference between-the current Cycle-10 operation'and Cycle 11 operation is that the reload fuel,will consist of the.GE9B' Fuel Design during Cycle 11 operation. Amendment 18 to GESTAR

-(NEDE-24011-P-A) incorporated the GE9B fuel design and received generic NRC approval in May of 1988. For this reason, Commonwealth Edison intends to employ the provisions in 10 CFR'50.59 for reviewing this.new. fuel design

'and will include the appropriate power distribution limits in' the Unit 2 COLR for Cycle 11. Therefore, issuance ~ of this amendment is needed to support the initial start-up of Quad Cities Nuclear Power Station Unit 1 Cycle,11, which is currently scheduled in November 1989. The Unit 2 Technical Specification changes will not be required until Cycle 11' operation begins in May of 1990, based on the current schedule.

C. DESCRIEUQlLQLIECHNICALSF1ClE1CAUON CHANSES Attachment 2 provides Technical Specificatico changes for removal of cycle specific power distribution limits and accompanying use of the COLR. The, following sections outline all areas requiring revisions and identifies the associated pages and sections of the Technical Specifications.

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Unit 1 Technical Specifications EAGI RQdS1 ESCRII21M OF CHAIE45 vli In List of Figures, deleted Figures 3.5-1 and 3.5-2.

1.0-l' Added new entry, " CORE OPERATING LIMITS REPORT", to Definition Section and switched the order of another definition to preserve the alphabetical order.

1.1/2.1-7 In Basis Section 1.1.A; incorporated reference to CORE OPERATING LIMITS REPORT.in place of LHGR limits.

1.1/2.1-10 In Limiting Safety System Bases, lucorporated reference to CORE OPERATING LIMITS REPORT in place of Paragraph 3.5.K for obtaining MCPR operating limits.

3.2/4.2-19/20 In Table 3.2-3. ' Instrumentation that Initiates Rod Block'; incorporated reference to CORE OPERATING LIMITS.

REPORT in place of Rod Block Monitor Upscale Setpoint relationship (added Note 10).

3.3/4.3-7 In Section 3.3.C; incorporated reference to CORE OPERATING LIMITS REPORT in place of 20% scram insertion time limit.

3'3/4.3-14

. In Basis Section 3.3.C; incorporated reference to CORE OPERATING LIMITS REPORT in place of 20% scram insertion time limits.

3.5/4.5-13/14 In Sections 3.5.I, 3.5.J and 3.5.K; incorporated reference to CORE OPERATING LIMITS REPORT in place of APLHGR, LHGR and MCPR limits respectively.

3.5/4.5-20 In Bases Sections 3.'5.I, 3.5.J and 3.5.K; incorporated reference to CORE OPERATING LIMITS REPORT in explanation of APLHGR, L1GR and MCPR limits.

3.5/4.5-26 In Basis Section 4.5; incorporated reference to CORE OPERATING LIMITS REPORT in KI correction factor explanation.

N/A Deleted Figure 3.5-1, Sheets 1 thru 5 (MAPLHGR Limits).

N/A Deleted Figure 3.5-2 (MCPR Kr Correction).

3.6/4.6-11 In Section 3.6/4.6.H; incorporated reference to CORE OPERATING LIMITS REPORT in place of MCPR and RBM Rod Block setpoint limits during Single Loop Operation.

3.6/4.6-24 'In Basis Section 3.6.H; incorporated reference to CORE OPERATING LIMITS REPORT in explanat!.on of MCPR and RBM Rod Block setpoint limits during Single Loop Operation. j 6.6-2 In Section 6.6.A, ' Reporting Requirements'; added a new j Section 6.6.4, entitled, " CORE OPERATING LIMITS REPORT".

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Unit 2 Technical Specifications ,

1 PAGE NO.(S) DESCRIPTION OF CHANGES vi In List of Figures, deleted Figures 3.5-1 and 3.5-2.

1.0-1 Added new entry, " CORE OPERATING LIMITS REPORT", to Definition Section and switched the order of another definition to preserve the alphabetical. order.

l 1.1/2.1-4 In Basis Section 1.1.A; incorporated reference to CORE OPERATING LIMITS REPORT in place of LHGR limits.

L 1.1/2.1-7 In Limiting Safety Syrtem Bases, incorporated reference to CORE OPERATING LIMITS REPORT in place of Paragraph 3.5.K for obtaining MCPR operating limits.

3,2/4.2-14/14a In Table 3.2-3, ' Instrumentation that Initiates Rod Block's incorporated reference to CORE OPERATING LIMITS REPORT in place of Rod Block Monitor Upscale Setpoint relationship (replaced Note 10).

3.3/4.3-5 In Section 3.3.C; incorporated' reference to CORE OPERATING LIMITS REPORT in place of 20% scram insertion time limit.

3.3/4.3-10 In Basis Section 3.3.C; incorporated reference to CORE OPERATING LIMITS REPORT in place of 20% scram time insertion time limits.

3.5/4.5-9/10 In Sections 3.5.I, 3.5.J and 3.5.K; incorporated reference to CORE OPERATING LIMITS REPORT in place of APLHGR, LHGR and MCPR limits respectively.

3.5/4.5-13/14 In Bases Sections 3.5.I and 3.5.J; incorporated reference to CORE OPERATING LIMITS REPORT in explanation of APLHGR and LHGR limits.

l 3.5/4.5-14a In Basis Section 3.5.K; incorporated reference to CORE  ;

OPERATING LIMITS REPORT in place of 20% scrmn insertion time limit.

3.5/4.5-18 In Basis Section 4.5; incorporated reference to CORE OPERATING LIMITS REPORT in Kf correction factor explanation.

N/A Deleted Figure 3.5-1, Sheets 1 thru 6 (MAPLHGR Limits).

N/A Deleted Figure 3.5-2 (MCPR Kg correction).

3.6/4.6-5a In Section 3.6/4.6.H; incorporated reference to CORE OPERATING LIMITS REPORT in place of MCPR and RBM Rod Block setpoint limits during Single Loop Operation.

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o Unit 2 Technical Specifications (Cont'd)

EAGE_EQdE1 DESCRIPTION OF CHhtlGES 3.6/4.6-13a In Basis Section 3.6.H; incorporated reference to CORE OPERATING LIMITS REPORT in explanation of MCPR limits during Single Loop Operation.

6.6-2 In Section 6.6.A, ' Reporting Requirements'; added a new Section 6.6.4, entitled, " CORE OPERATING LIMITS REPORT".

D. SATIIY_JVA!ALATION

SUMMARY

The preceding discussion has addressed the removal of cycle specific power distribution limits from the Technical Specifications of Quad Cities Nuclear Power Station Units 1 and 2, and referencing of a unit specific Core Operating Limits Report per Generic Letter 88-16. Since CECO will continue to assure that NRC approved methodology and fuel types are utilized for each reload application and will submit the COLR for NRC information and trending, Commonwealth Edison concludes that the proposed changes do not represent an unreviewed safety question and are acceptable to facilitate 10 CFR 50.59 reviews of future reloads (with Edison having responsibility for updating the cycle specific power distribution limits) l for Quad Cities Unit 1 Cycle 11, Quad cities Unit 2 Cycle 11, and future Quad Cities operating cycles. This conclusion is valid provided that the l following items are completed prior to startup of Cycle 11 operation for each unit:

a. The attached Technical Specifications are NRC epproved; and Quad Cities procedures are modified to be consistent with the revised i Technical Specifications.

b. A Quad Cities Administrative Procedure (QAP) is developed to control implementation and revision of each Unit's Core Operating Limits Report.

c. The GE9B fuel design is reviewed per 10 CFR 50.59 for the Unit 2 Cycle 11 application, and the 6ppropriate power distribution limits ,

are added to each units Core Operating Limits Report. l As required by 10 CFR 50.92(c), significant hazards considerations have been evaluated in Attachment 3. i l

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