Text

Proposed Tech Specs Re HPCI & RCIC Sys Testing Requirements
	ML20247J930
Person / Time
Site:	Quad Cities
Issue date:	03/21/1989
From:	; COMMONWEALTH EDISON CO.
To:	;
Shared Package
ML20247J927	List: ML20247J923; ML20247J930;
References
	NUDOCS 8904050119
	Download: ML20247J930 (27)
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PROPOEED_.CHANGIS._IO APPENDJX._A IECRtLChk liEEC1ElEhT1DUS 1DE l

l OUAD CITIES _.UNlTS 1 AND 2 i DER-23 DPlL-10 3.5/4.5-5 3.5/4.5-4a 3.5/4.5-6 3.5/4.5-5 3.5/4.5-7 3.5/4.5-6 3.5/4.5-8 3.5/4.5-6a 3.5/4.5-23 3.5/4.5-15 3.5/4.5-15a ,

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l 5578k 8904050119 890321 PDR ADOCK 05000254 P PDC t - _ _ _ _ _ _ _ - _ - -

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' QUAD-CITIES DPR-29

4. Containment cooling spray loops 4. During each 5 year period, an are required to be operable when air test shall be performed on the reactor water temperature is the drywell spray headers and greater than 212 F and prior to nozzles and a water spray test reactor startup from a cold con- performed on the torus spray

dition. Continued reactor oper- header and nozzles.

ation is permitted provided that 2.

a maximum of one drywell spray Durinc3 etartupptiowing a rejukl ou.tage or an.oulage loop may be inoperable for 30 days when the reactor water tem- in which werk was erformed 4hd dircct!Y perature is greater than 212 F. ageds HPCI r yst6vv1 opraEhty, if the festiruj '

5. If the requirements of ? 5.8 r64.u.iremenLs. of 4.5 C,3 cannel be md.,

cannot be met, an orde, y shut- continued reu. tov startup is ocL perm &d.

down shall be initiated, and the reactor shall be in a cold shut- The RPCI ou.bepbem shall b6 d4ciered inoperable7 down condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . and th6 provisions cf Spcificobdn e.s.c.4 C. HPCI Subsystem hall be imPlcrhenkcd HPCI Subsystem Css 4 inu.rQ

- Surveil:ance of HPCI sub;y; tem ch;M be performed as fellows: p

1. The HPCI subsystem shall be HPCI subsystem testing sha be operable whenever the reactor as specified in Specifica ions pressure. is greater than 60-150 4.5.A.1.a, b, c, and d, xcept add psigx M 2dicted fuel is in the hat the HPCI pump shal deliver reactor vesseix.and prier to re- a least 5000 gpm agai st a sys-ac-tor startup from a colri e n n rH - te head corresponds to a re-t h n: acto vessel pressu j of 1150 psig 150 psig, nd a logic D"

system nctional test shall be performe durin each refueling

3. Except {er thg hmihtbons of 3.5.c.23y K. frem and after the date that the 2. When it is d rmined that the HPCI subsystem is made or found HPCI subsys m 's inoperable, to be inoperable,f-cr any rencon,- the LPCI m e of the RHR system, continued reactor operation is both core spray s systems, the g permissible only during the suc- automati pressure elief sub-ceeding days unless such sub- system, and the RCIC stem system is sooner made operable, shall e demonstrated be op-provided that during such ys erab immediately. Th RCIC e44-ee W e ccmponentt-of the g sys em shall be demonstra ed to automatic pressure relief sub- be operable daily thereaft .

systems, the core spray sub- D ily demonstration of the a to-systems, LPCI mode of the RHR aticpressure.reliefsubsysth system, and the RCIC system are operable. Otherwis6,h prossions cj 5peci{ica. tion 3.5.CA shajl be imphmmted.

3.5/4.5-5 Amendment No. 114

t INSERT FOR TECHNICAL SPECIFICATION PAGE 3.5/4.5-5 C. Surveillance of the HPCI subsystem shall be performed as specified below with the following limitations. For i tem 4.5.C.3, the plant is allowed 12 l hours in which to successfully complete the test once reactor vessel l

pressure is adequate to perform each test. In addition, the testing required by item 4.5.C.3.a shall be completed prior to exceeding 325 psig reactor vessel pressure. If HPCI is made inoperable to perform overspeed testing, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to complete the tests before exceeding 325 psig.

Item Frequeng

1. Valve Position Every 31 days

2. Flow Rate Test - HPCI Pump Every 92 days shall deliver at least 5000 gpm against a system head corresponding to a reactor vessel pressure of 2 1150 psig when steam is being supplied to the turbine at 920 to 1005 psig.

3. Flow Rate Test-HPCI pump During startup following a refuel shall deliver at least 5000 outage or an outage in which work gpm against a system head was performed that directly correspor. ding to a reactor affects HPCI system operability.

vessel pressure of:

a. 2 300 polg when steam is being supplied to the turbine at 250 to 325 psig, and

b. 2 1150 psig when steam is being supplied to the turbine at 920 to 1005 psig.

4. Simulated Automatic Each refueling outage Actuation Test

5. Logic System functional Test Each refueling outage

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1662H/0524Z

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QUAD-CITIES DPR-29 l

rability is not requir /

prov' d that two fee - er j pumps ar peratin t levels j above 300 F -

d one feedwater i pump is ope 1 as normally i require 7th one a 'tional J fee er pump operable t. power

, a. s . c. I , 3. s .c. 2. or 3. s .c.3 , els less than 300 MWe.

1 4:/. If the requirement o Specification .. cannot be l met, an orderly shutdown shall '

be initiated, and the reactor pressure shall be reduced to 90 4160 i

psig within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

D. Automatic Pressure Relief Subsystems D. Automatic Pressure Relief Subsystems Surveillance of the automatic pressure relief subsystem shall be performed as follows:

(

1. The automatic pressure relief 1. The following surveillance shall subsystem shall be operable be carried out on a six month whenever the reactor pressure is surveillance interval:

greater than 90 psig, irradiated fuel is in the reactor vessel ,a . With the reactor at pressure and prior to reactor startup each relief valve shall be from a cold condition. manually opened. Relief 1 valve opening shall be verified by a compensating turbine bypass valve or I

1 control valve closure. I

2. From and after the date that two 2. A logic system functional test j of the five relief valves of the shall be performed each automatic pressure relief refueling outage.

subsystem are made or found to be inoperable when the reactor is pressurized above 90 psig with irradiated fuel in the reactor vessel, reactor operation is permissible only during the succeeding 7 days unless repairs are made and provided that during such time the HPCI subsystem is operable. .

3.5/4.5-6 Amendment No. 114

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,. QUAD-CITIES DPR-29 i

l 3. If the requirements of Specifi- 3. A simulated automatic initiation cation 3.5.D cannot be met, an which opens all pilot valves orderly shutdown shall be initi- shall be per formed each re-ated and the reactor pressure fueling outage.

shall be reduced to 90 psig within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

4. When it.is determined that two valves of the automatic pressure 3 relief subsystem are inoperable, the HPCI shall be demonstrated to be open..ble-immediately.

seeinserD E. Reactor Core Isolation' Cooling System E. Reactor Core Isolation Cooling System rveillance of the RCIC system sha be erformed as follows: .

1. The RCIC system will be operable 1. IC system testing shall e as whenever the reactor pressure is sp ified in Specificat' n i greater than 150 psig, irradi "'2nd 4.5. 1.a, b, c, and except I ated fuel is in the reactor ves- that e RCIC pump s 11 deliver I selg.and prier te startup < rem a at leas 400 gpm a inst a sys- I colm condition, tem head rrespo ding to a re-actor vesse pr sure of 1150 ,

) psig to 150 g, and a logic l system funct'o 1 test shall be I run during ach fueling outage, acept for fhe hmtta.Lichs of S.S.E.2.,if I f.3.fromcndofterthedrtethat.the 2. When it is determin that the RCIC system is made or found tu RCIC stem is inoperd;1e, the be inoperable,for any rec;cm HPC system shall be de n-continued reactor operation is st ated to be operable i edi-permissible only during the suc- ely and daily thereafter.

14 ceeding4 days unless such sys- I tem is sooner made operable g4 l

-c' provided that during such Ydays !

eli active component +-of the _

HPCI system operable, othcrdisy !

the previsions of Spaificafjon S.S.E.4 sh&\l be imp l6m6nted.

2. During startup felicdng a. reju.el od.ge t r an outa.ge i.n u>hich wer k was perforrned the t di.re.cEly af ec.ts &c RCIC syefem oferdili , if the Eest.(ng requwtrnents % 4.5.E.S ca.nnot bc. met ,

conEinaed redder sta.rtg is not. perrnitted. The RCl(-

qstem cha.tl be de c.laml inoperdl% and the- provimons of sp e c.t { i<.cLt. ion s. e.E.4 3.5/4.5-7 Amendment No. 114 ebo.ti be implemented.

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l INSERT FOR TECHNICAL SPECfFfCATf0N PAGE 3.5/4.5-7 l

l E. Surveillance of the RCIC system shall be performed as specified below with the following limitations. For item 4.5.E.3, the plant is allowed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in which to successfully complete the test once reactor vessel pressure is 1 adequate to perform each test. In addition, the testing required by item 4.5.E.3.a shall be completed prior to exceeding 325 psig reactor vessel pressure. If RCIC is made inoperable to perform overspeed testing, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to complete the tests before exceeding 325 psig.

Item Frequency

1. Valve Position Every 31 days

2. Flow Rate Test - RCIC Pump Every 92 days i shall deliver at least 400 I gpm against a system head !

corresponding to a reactor ;

vessel pressure of 2 1150 l psig when steam is being ;

supplied to the turbine at I 920 to 1005 psig. l l 3. Flow Rate Test-RCIC pump During startup following a refuel shall deliver at least 400 outage or an outage in which work ,

gpm against a system head was performed that directly l corresponding to a reactor affects RCIC system operability. l vessel pressure of:

1

a. 2 300 psig when steam !

is being supplied to ,

the turbine at 250 to '

325 psig, and '

b. 2 1150 psig when steam is being supplied to the turbine at 920 to 1005 psig.

4. Simulated Automatic Each refueling outage Actuation Test

5. Logic System Functional Test Each refueling outage l

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j 1662H/0524Z i _ __ __

QUAD-CITIES DPR-29 ror 3.5.E.S

3. If the requirements y of Specification cannot be met, an 3.5.E.1,w d 3.5.E.2'all orderly s'iutdown sh be initiated i and the react.or pressure shall be !

reduced to M psig within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

fa3o l ing the period November 6 thro ;

Nove r 20, 1976 the unit ma e started u with the RCIC

perable provided t(hats. 1) the ility is not more than 7 day the RCIC inoperable and the HPCI '

system ac,ti componen re demonst ed to be operabl l imm ately after startup and Q

l ereafter. l 3

F. Minimum Core and Containment Cooling F. Minimum Core and Containment Cooling System Availability System Availability

1. Any combination of inoperable Surveillance requirements to assure components in the core and that minimum core and containment l containment cooling systems cooling systems are available have l shall not defeat the capability been specified in Specification 4.2.8. (

of the remaining operable I components to fulfill the core and containment cooling functions.

2. When irradiated fuel is in the reactor vessel and the reactor '

is in the cold shutdown condition, all low pressure core and containment cooling systems may be inoperable provided no sork is being done which has the potential for draining the taactor vessel.

3.5/4.5-8 Amendment No. 114 e________-

a QUAD-CITIES DPR-29 4.5 SURVEILLANCE REQUIREMENTS BASES The testing interval for the core and containment cooling systems is based on a quantitative reliability analysis, judgment, and practica'ity. The core cooling systems have not been designed to be fully testable during operation. For example, the core spray final admission valves do not open until reactor pressure has fallen to 350 psig. Thus, during operation, even if high drywell pressure were simulated, the final valves would not open. In the case of the HPCI, I automatic initiation during power operation would result in pumping cold water

--+ into the reactor vessel which is not desirable. ;

The systems can be automatically actuated during a refueling outage and this will i be done. To increase the availability of the individual components of the core and containment cooling systems, the components which make up the system, i.e.,

instrumentation, pumps, valve operators, etc., are tested more frequently. The instrumentation is functionally tested each month. Likewise the pumps and. ,

motor-operated valves are also tested each month to assure their operability. '

The combination of a yearly simulated automatic actuation test and monthly tests ,

of the pumps and valve operators is deemed to be adequate testing of these systems.j combine, paragnyhs, EWithcomponentsorsubsystemsoutofservice,overallcoreandcontainment cooling reliability is maintained by demonstrating the operability of the remaining cooling equipment. The degree of operability to be demonstrated depends on the nature of the reason for the out-of-service equipment. For routine out of-service periods caused by preventative maintenance, etc. , the pump and valve operability checks will be performed to demonstrate operability.of the remaining components. However, if a failure, design deficiency, etc., causes the out-of service period, then the demonstration of operability should be thorough enough to assure that a similar problem does not exist on the remaining components.

For example, if an out of service period is caused by failure of a pump to deliver rated capacity due to a design deficiency, the other pumps of this type might be subjected to a flow rate test in addition to the operability checks.

l Cnsert new paragreb. see abhedd The verHication of tie main steam relief valve operability during manual actuation surveillance testing must be made independent of temperatures indicated by thermocouple downstream of the relief valves. It has been found that a temperature increase may result with the valve still closed. This is due to steam being vented through the pilot valves during the surveillance test. By I first opening a tureine bypass valve, and then observing its closure response during relief valve actuation, positive verification can be made for the relief valve opening and passing steam flow. Closure response of the turbine control valves during relief valve manual actuation would likewise serve as an adequate verification for the relief valve opening. This test method may be performed over a wide range of reactor pressures greater than 150 psig. Valve operation below 150 psig is limited by the spring tension exhibited by the rel,ief valves.

The earveillance r9uremeni bued described in ens paracjra.ph gph fo ph core and con %hment coefg systerns except. 'Act cmd APG 3.5/4.5-23 Amendment No. 114

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. INSERT FOR TECHNICAL SPECIFICATION PAGE 3.5/4.5-23 The surveillance requirements bases described in this paragraph epply only to the RCIC and HPCI systems. With a cooling system out of service, overall. core and containment cooling reliability is maintained by verifying the operability of the remaining cooling systems. The verification of operability, as used in this context, for the remaining cooling systems means to administratively l check by examining logs or other information to verity that the remaining 1 systems are not out-of-service fcr maintenance or other reasons. It does not l mean to perform the surveillance requirements.needed to demonstrate the' ,

operability of the remaining systems. However, if a failure, design l deficiency, etc., causes the out-of-service period, then the verification of operability should be thorough enough to assure that a similar problem does i not exist on the remaining systems. For example, if an out-of-service period is caused by failure of a pump to deliver rated capacity due to a design i deficiency, the other pumps of this type might be subjectea'to a flow rate 'I test. Following a refueling outage or an outage in which work was performed l that directly affects system operability the HPCI and RCIC pumps are flow rate tested prior to exceeding 325 psig and again at rated reactor steam pressure. This combination of testing provides adequate assurance of pump l performance throughout the range of reactor pressures at which it is required to operate. The low pressure limit is selected to allow testing at a point of stable plant operation and also to provide overlap with low pressure'ECC systems. A time limit is provided in which to perform the required tests during start-up. This time limit is considered adequate to allow stable plant conditions to be achieved and the required tests to be performed. Flow rate i testing of the HPCI and RCIC pumps is also conducted every 92 days at rated reactor pressure to demonstrate system operability in accordance with the LC0 provisions and to meet inservice testing requirements for the HPCI system.

Applicable valves are tested in accordance with the provisions of the l inservice testing program. In addition, monthly checks are made on the position of each manual, power operated or automatic valve installed in the direct flowpath of the suction or discharge of'the pump or turbine that is not locked, sealed, or otherwise secured in position. At each refueling outage, a

logic system functional test and a simulated automatic actuation test is l performed on the HPCI and RCIC systems. The tests and checks described above are considered adequate to assure system operability.

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1662H/0524Z L

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QUAD-CI7IES i , DPR-30 C. HPCI Subeystem C. HPCI Subsystem Surveillance of the HPCI subsystem shall be performed as specified below with the following limitations. For item 4.5.C.3, the plant is allowed 12 .

hours in which to successfully )

complete the test once reactor 3 pressure is adequate to perform each !'

test. In addition, the testing required by item 4.5.C.3.a shall be completed prior to exceeding 325 psig reactor vessel pressure. If HPCI is .

made inoperable to perform overspeed j testing. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to' 'l' complete the tests before exceeding 325 psig.

EgD freauency .

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1. The HPCI subsystem shall be 1 Valve Position Every 31 days 1 i

operable whenever the reactor ] '

l pressure is greater than 150 I psig and fuel is in the reactor l vessel.

2. During sta'r tup following a 2. Flow' Rate Test - Every 92 days }

refuel outage or an outage in HPCI purp shall which work was performed that deliver at least directly affects HPCI system 5000 gpm against L operability, if the testing a system head requirements of 4.5 C.3 cannot corresponding be met, continued reactor to a reactor

' startup is not permittcd. The vessel pressurc HPCI subsystem shall te declared of 11150 psig when j Inoperable, and the provisions steam is being of Specification 3.5.C.A shall supplied to the be implemented. turbine at 920 to 1005 psig.

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3. Except for the. limitations of 3. Flow Rate Test . During i 3.5.C.2 if the HPCI subsystem HPCI pump shall startup l 1s made or found to be deliver at least following l inoperable, continued reactor 5000 gpm against a refuel

, operation is permissible only a system head outage I during the succeeding 14 days corresponding to. or an outage j l unless such subsystem is sooner a reactor vessel in which work '

made operable, provided that pressure of: was performed during such 14 days the a. 1 300 psig that directly automatic pressure relief when steam is affects HPCI subsystem, the core spray being supplied system subsystems. LPCI mode of the RHR to the turbine operability, system, and the PCIC system are 'at 250 to '325 operable. Otherwise, the psig, and-provisions of Specification b. 1 1150 psig when 3.5.C.4 shall be implemented, steam is being supplied to the turbine at 920 to 1005 psig.

4. If the requirements of 4. Simulated Each refueling Spe:' t f ication 3.5.C.1. 3.5.C.2 Automatic outage ;

or 3.5.C.3 cannot be met, an Actuation Test j orderly shutdown shall be j initiated, and the reactor 5. Logic System Each refueling i pressure shall be reduced to Functional outage

<150 psig within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Test

.i N 1615H/05052 3.5/4.5-4a Amendment No.

v QUAD-CETIES DPR-30 D. Automatic Pressure Relief Subsystems D. Automatic Pressure Relief Subsystems Surveillance of the automatic pressure relief subsysten shall be performed as follows:

1. The automatic pressure relief 1. The following surveillance shall subsystem shall be operable be carried out on a six-month whenever the reactor pressure is surveillance interval' greater than 90 psig. irradiated I fuel is in the reactor vessel a. With the reactor at pressure .;

and prior to reactor startup each relief valve shall be from a cold condition, manually opened. Relief valve opening shall be verified by a compensating turbine bypass valve or control valve closure.

2. From and after the date that two 2. A logic system functional test of the five relief valves of the shall be performed each j automatic pressure relief refueling outage.

subsystem is made or found to be inoperable when the reactor is pressurized above 90 psig with irradiated fuel in the reactor vessel. reactor operation is permissible only during the succeeding 7 days unless repairs are made and provided that during such time the HPCI subsystem is operable.

3. If the requirements of 3pecifi- 3. A simulated automatic initiation cation 3.5.0 cannot be met. an which opens all pilot valves orderly shutdown shall be initi- shall be performed each re-ated and the reactor pressure fueling outage.

shall be reduced to 90 psig within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

4 When it is determined that two relief valves of the automatic pressure relief subsystem are inoperable, the HPCI shall be demonstrated to be operable innediately.

i-1615H/0505Z 3.5/4.5-5 Amendment No.

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QUAD-CITIES

, DDR-30 E. Reactor Core Isolation Cooling System E. Reactor Core Isolation Cooling System Surveillance of the RCIC system shall be performed as specified below with the following limitations. For item 4.5.E.3, the plant is allowed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in which to successfully complete the test once reactor vessel pressure is adequate to perform each test. In addition, the testing required by item 4.5 E.3.a shall be-completed prior to exceeding 325 psig l reactor vessel pressure. If RCIC is I made inoperable to perform overspeed j testing. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to l complete the tests before exceeding 325 psig.

Regi Frecuency

1. The RCIC cystem will be operable 1. Valve Position Every 31 days l whenever the reactor pressure is

! greater than 150 psig and fuel l is in the reactor vessel.

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2. During startup following a .2 . Flow Rate Test - Every 92 days refuel outage or an outage in RCIC pump shall which work was performed that deliver at least directly affects RCIC system 400 gpm against operability. if the testing a system head requirements of 4.5.E.3 cannot corresponding be met, continued reactor to s reactor startup is not permitted. The vessel pressure RCIC system shall be declared of 11150 psig when i inoperable, and the provisions steam is being j of Specification 3.5.E.4 shall Jpplied to the l be implemented, turbine at 920 to i 1005 osig.

3. Except for the limitations of 3. Flow Rate Test - During l 3.5.E.2. if the RCiC system is RCIC pump shall startup j made or found to be inoperable. deliver at least following j continued reactor operation is 400 gpm against a refuel '

permitted only during the a system head outage succeeding 14 days unless such corresponding to or an outage system is sooner made operable, a reactor vessel in which work provided that during such 14 pressure of: was performed days the HPCI system is a. 1 300 psig that directly operable. Otherwise, the when steam is affects RCIC i provisions of Specification being supplied system l 3.5.E.4 shall be implemented, to the turbine operability. ,

at 250 to 325 '

psig, and

b. 1 1150 psig when steam is being supplied to the turbine at 920 to 1005 psig.

4. If the requirements of 4. Simulated Each refueling Specification 3.5.E.1. 3.5.E.2 Automatic outage or 3.5.E.3 cannot be met, an Actuation Test orderly shutdown shall be initiated and the reactor 5. Logic System Each refueling pressure shall be reduced to Functional outage

<150 psig within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Test

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.W 1615H/05052 3.5/4.5-6 Amendment No.

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QUAD-CITIES DPR-30 F. Minimum Core and Containment Cooling F. Minimum Core and Containment Cooling System Availability System Availability Surveillance requirements to assura that minimum core and containment cooling systems are available have been specified in Specification 4.2.8.

1. Any combination of inoperable components in the core and containment cooling systems shall not defeat the capability of the renaining operable components to fulfill the core and containment cooling functions,

2. When irraciated fuel is in the reactor vessel and the reactor is in the cold shutdown condition. all low-pressure core and containment cooling systems may be inoperable provided no work l

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0 1615H/0505Z 3.5/4.5-6a Amendment No.

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. 4.5 SURVEILLANCE REQUIREMENTS BASES 4 The testing interval for the core and containment cooling systems is based on a l quantitative reliability analysis, judgment, and practicality. The core cooling systems have riot been designet to be fully testable during operation. For example, the core spray final admission valves do not open until reactor pressure j has fallen to 350 psig. Thus, during operation, even if high drywell pressure were simulated, the final valves would not open. In the case of the HPCI, automatic initiation during power operation would result in pumping cold water into the reactor vessel which is not desirable.

The surveillance requirements bases in this paragraph apply to all core and I containment cooling systems except RCIC and HPCI. The systems can be '

automatically actuated during a refueling outage and this will be done. To increase the availability of the individual components of the core and containment cooling systems, the components which make up the system, i.e.,

instrumentation, pumps, valve operators, etc., are tested more frequently. The instrun.entation is functionally tested each month. Likewise the pumps and motor-operated valves are also tested each month to assure their operability.

The combination of a yearly simulated automatic actuation test and monthly tests of the pumps and valve operators is deemed to be adequate testing of these systems. With components or subsystems out of service, overall core and containment cooling reliability is maintained by demonstrating the operability of .

the remaining cooling equipment. The degree of operability to be demonstrated l depends on the nature of the reason for the out-of-service equipment. For routine out-of-service periodi caused by preventative maintenance, etc., the pump l l and valve operability checks will be performed to demonstrate operability of the ;

remaining components. However, if a failure, design deficiency, etc., causes the out-of-service period, then the demonstration of operability should be thorough enough to assure that a similar problem does not exist on the remaining components. For example, if an out-of-service period caused by failure of a pump to deliver rated capacity due to a design deficiency, the other pumps of this type might be subjected to a flow rate test in addition to the operability checks.

The surveillance requirements bases described in this paragraph apply only to the RCIC and HPCI systems. With a cooling system out of service, overall core and containment cooling reliability is maintained by verifying the operability of the l remaining cooling systems. The verification of operability as used in this context, for the remaining cooling systems means to administrative 1y check by examining legs or other information to verify that the remaining systems are not out-of-service for maintenance or other reasons. It does not mean to perform the surveillance requirements needed to demonstrate the operability of the remaining systems. However, if a failure, design deficiency, etc., causes the out-of-service period, then the verification of operability should be thorough l

enough to assure that a similar problem does not exist on the remaining systems.

For example, if an out-of-service period is caused by f ailure of a pump to deliver rated capacity due to a design deficiency, the other pumps of this type might be subjected to a flow rate test. Following a refueling outage or an outage in which work was performed that directly affects system operability, the HPCI and RCIC pumps are flow rate tested prior to exceeding 325 psig and again at rated reactor steam pressure. This combination of testing provides adequate assurance of pumn performance throughout the range of reactor pressures at which it is required to optrate. The low pressure limit is selected to allow testing at a point of stable plant operation and also to provide overlap with low pressure ECC systems. A time limit is provided in which to perform the ree.uired I tests during startup. This time limit is considered adequate to allow stable I

plant conditions to be achieved and the required tests to be performed. Flow rate testirig of the HPCI and RCIC pumps is also conducted every 92 days at rated l reactor pressure to demonstrate system operability in accordance with the LCO l provisions and to meet inservice testing requirements for the HPCI system.

l Applicable valveh are tested in accordance with the provisions of the inservice testing program. In addition, monthly checks are made on the cosition of each manual, power operated or automatic valve installed in the direct flowpath of the

! suction or dis:harge of the pump or turbine that is not locked, sealed, or otherwise secured in position. At each refueling outage, a logic system functional test and a simulated automatic actuation test is performed on the HPCI and RCIC systena. The tests and checks described above are considered adequate to assure system operability.

The verification of the main steam felief valve operability during manual actuation surveillance testing must be made independent of temperatures indicated by thermocouple downstream of tne relief '.alves. It has been found that a temperature increase may result with the valve still closed. This is due to steam being vented through the pilot valves during the survet11ance test. By 1615H/0505Z 3.5/4.5-15 Amendment No.

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QUAD-CITIES DPR-30 I .first opening a turbine bypass valve, and then observing its closure response during

. relief valve actuation, positive verification can be made for the relief valve opening and passing steam flow. Closure response of the turbine control valves during reitef valve manual actuation would likewise serve as an adequate verification for the relief valve opening. Ti.is test method may be performed over a wide range of reactor pressures greater than 150 psig, Valve operation below 150 psig is limited by the spring tension exhibited by the relief valves.

The surveillance requirements to ensure that the discharge piping of the core spray, LPCI mode of the RHR, HPCI, and RCIC systems is filled provides for a visual observation that water flows fran a high point vent. This ensures that the line is in a full condition.

Instrumentation has been provided on core spray and LPCI mode of RHR to monitor the pressure of water in the discharge piping between the monthly intervals at which the lines are vented and alarm the control room if the pressure is inadequate. This instrumentation will be calibrated on the same frequency as the safety system instrumentation and the alarm system tested monthly. This testing ensures that, during the interval between the monthly venting checks, the status of the discharge piping is monitored on a continuous basis. An alarm point of 40 psig for the low pressure of the l fill system has been chosen because, due to elavations of piping within the plant, 39 >

psig is required to keep the lines full. The shutoff head of the fill system pumps is less than 90 psig and therefore will not defeat the low-pressure cooling pump discharge press interlock 100 psig as shown in Table 3.2-2. A margin of 10 psig is provided by the high pressure alarm point of 90 psig. I 1

HPCI and RCIC systems normally take a suction from the Contaminated Condensate Storage Tanks (CCST's). The level in the CCST's is maintained at or above 9.5 feet. This level l corresponds to an elevation which is greater than the elevation of the last check valves in the discharge pipes of either the HPCI or RCIC systems. Therefore, f111ed discharge piping of HPCI or RCIC systems is ensured when lined up to the CCST and tank level is at or above 9.5 feet.

l l The watertight bulkhead and submarine doors and the penetration seals for pipe and l cables penetrating the vault walls and ceilings have been designed to withstand the i maximum flood conditions. To assure that their installation is adequate for maximum l flood conditions, a method of testing each seal has been devised. !

i l In order to test an electrical penetration or pipe seal, compressed air is supplied to a test connection and the space between the fittings is pressurized to approximately 15 psig. The outer f aces are then tested for leaks using a soap bubble solution.

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.;W 1615H/0505Z 3.5/4.5-15a Amendment No. I L l

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ATIACIMDIL2 SUNMARY OF CilAt[GES 1

The following changes have been identified for Quad Cities Station Units 1 and 2 Technical Specifications:

1. .Pages 3.5/4.5-5 and 3.5/4.5-6 (DPR-29)

Pages 3.5/4.5-4a and 3.5/4.5-5 (DPR-30)

(a) Limiting Condition for Operation (LCO), Technical Specification 3.5.C.1.

Change the requirement for HPCI to be operable from greater than 90 psig and irradiated fuel in the reactor vessel to greater than 150 psig and fuel in the reactor vessel.

Delete the HPCI operability requirement prior to a reactor startup from a cold condition.

(b) LCO Technical Specification 3.5.C.2

Renumber the specification to 3.5.C.3 to accomodate a new Specification 3.5.C.2

Change the 7 days allowance for the system out of service time to 14 days.

State that this specification shall not apply during the conditions described in Specification 3.5.C.2, i.e., during startup following a refuel outage or an outage in which work was performed that directly affected HPCI system operability.

Require that the provisions of Specification 3.5.C.4 be implemented if the provisions of the specification cannot be met.

(c) LCO Technical Specification 3.5.C.2 (new)

Provide limitations for continued reactor startup from a refuel outage or an outage in which work was performed that directly affected HPCI system operability.

Add a statement which invokes the implementation of Specification 3.5.C.4 in'the event that the testing requirements, as delineated in Specification 4.5.C.3, cannot be met.

. t. ,L (d) LCO Technical Specification 3.5.C.3. 'l

Renunber specification to 3.5.C.4. ;

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Change the reactor pressure reduction requirement from'90 psig to 150 psig. ,

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Change the reference from Specification 3.5.C to Specification 3.5.C.1, 3.5.C.2, or C.S.C.3.

(e) Surveillance Requirements 4.5.C.1 and 4.5.C.2 1

Delete current ilPCI testing requirements and replace with testing based on Standard Technical Specifications.

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2. 'Pages 3.5/4.5-7 and 3.5/4.5-8 (DPR-29).

Pages 3.5/4.5-6 (DPR-30)

(a) LCO Technical Specification 3.5.E.1 >

Change RCIC system operability requirement from whenever 1 Irradiated fuel is in the reactor vessel to whenever fuel is in the reactor vessel.

Delete the RCIC operability requirement prior to a reactor startup from a cold condition.

(b) LCO Technical Specification 3.5.E.2 l

Renumber the specification to 3.5.E.3 to accommodate a new Specification 3.5.E.2.

Change the 7 day allowance for the system out of service time to 14 days. l l

State that the Specification shall not apply during the conditions described in 3.5 E.2, i.e., during startup following a refuel j outage or following an outage in which work was performed that' directly affected RCIC system operability.

Require that the provisions of Specification 3.5.E.4 be.

Implemented if the provisions of the Specification cannot be met. ;

(c) LCO Technical Specification.3.5.E.2 (new)

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Provides limitations for continued reactor startup'from a refuel outage or an outage in which work was performed that directly affected the RCIC system operability. l 1

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Add a statement which invokes the imp]ementation lof Specification 3.5.E.4 in the event that the RCIC. testing requirements, as-delineated in Specification 4.5.E.3,.cannot be met.

(d) .LCO Technical Specification 3.5.E.3.

Renumber as 3.5.E.4.

Change the reactor pressure reduction requirement from 91 psig to 150 psig.

Change the' reference from Specifications 3.5.E.1 and 3.5.E.2 to Specifications 3.5.E.1, 3.5.E.2 or 3.5.E.3.

(e) Surveillance Requirements 4.5.E.1 and 4.5.E.2.

Delete current RCIC testing requirements and replace with tostlag based on the Standard Technical Specifications.

3. Page 3.5/4.5-8 (DPR-29) l (a) LCO Technical Specification 3.5.4

Delete the exception to allow a unit startup with an inoperable RCIC system during the period November 6-20, 1976.

4. Page 3.5/4.5-23 (DPR-29)

Page 3.5/4.5-15 (DPR-30)

(a) Surveillance Requirement Bases 4.5 l

The bases have been revised to require verification of remaining system operability in lieu of an operability demonstration.vla the conduct of surveillance; The operability verification definition j was added as well as a description'of the bases for'PPCI and RCIC system operability.

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ATTACIMQiL3 DISfRJfTIGLMP_ILASIS FOR AMENDMENT REOUIS.T llP.CLRPERAfJlidTX Current Technical Specification 3.5.C, HPCI System requires the HPCI system to be operable whenever the reactor pressure is greater than 90 psig, irradiated fuel in the reactor vessel and prior to reactor startup from a cold condition. If the requirements of the 3.5.C.1 and 3.5.C.2 are not met, the Technical Specifications require an orderly shutdown with a reduction in reactor pressure to 90 psig.

The proposed Technical Specification requires the HPCI system to be operable whenever the reactor pressure is greater than 150 psig and fuel is in the reactor vessel. If the requirements are not met, the proposed change requires an orderly shutdown with a reduction in reactor pressure to 150 psig.

The present LCO requirement of 90 psig for operability of HPCI is not based on HPCI subsystem design or testing requirements. The HPCI systea (FSAR Table 6.2.6) is designed to pump 5000 gpm into the reactor vessel within a reactor pressure range of 1150 psig to 150 psig. For pressure lower than

) 150 psig, flow is estimated to decrease linearly to zero at 50 psig reactor pressure. The proposed change to 150 psig will retain a large margin of overlap with the low pressure cooling systems which will inject water to the reactor at approximately 325 psig. One of the HPCI automatic isolations signals is low steam line pressure of less than 100 psig (FSAR Table 7.7.2).

Since the HPCI is isolated below 100 psig in the steam line, the present LCO requirement of 90 psig for operability of HPCI should be increased. The proposed change to the shutdown pressure reduction to 150 psig provides consistency between the operability and shutdown pressures. The proposed change to 150 psig is supported by system design and flow and pressure and provides a margin to the present setpoint for system isolation on low steam line pressure.

The proposed change deletes the requirement for HPCI operability prior to a reactor startup. The HPCI system cannot be operable until the reactor pressure is adequate for system operation; therefore, HPCI cannot be operable prior to a reactor startup from a cold condition. This change is considered to be administrative in nature and is being made to clarify the current requirements.

The proposed change from " irradiated fuel" to " fuel" in the reactor vessel for HPCI operability is considered to be more conservative and administrative in nature.

IIECL QULQf_SEIWlEE_ TlMf_ALLOWMCE Current Technical Specifications require t'.'t from and after the date the HPCI rubsystem is made or found to be inoperable, continued reactor operation is permitted for 7 days. The proposed change creates a new 3.5.C.2 which describes act.ans to be taken during a startup from a refuel outage or an outage in which work was performed that directly affected HPCI operability.

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, The old 3.5.C.2 has been renumbe* ed as 3.5.C.3 and is applicable for the conditions other than describe 6 in Section 3.5.C.2. The allowed out of service time in the p 7 posed 3.5.C.3 has been extended from 7 days to 14 days.

The proposed out of service period for the HPCI system from 7 days to 14 days adopts the philosophy of'later BWR operating plants at Quad Cities q for the HPCI systems. -The proposed period reflects a low probability of the need for the system and reflects the availability,of low and high pressure core cooling systems for post accident mitigation functions.

A statement is proposed to the new Specification.3.5.C.3 (current Specification 3.5.C.'2) to indicate that the specification is not applicable j durire reactor startup from refuel outages or=an outage in whlch work was performed that directly affected HPCI operability. .The actions required during I

these conditions are addressed under the proposed Specification 3.5.C.2.

Separation of the conditions provides clarification to the required action'in the event of an inoperable system. The proposed revision includes a statement )

that requires an orderly shutdown if the specifications requirements are not-met. .

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1[ECI_SURVEI.LLANCE REOUIREMQiIS Current Technical Specifications require HPCI testing to be performed ns follows:

Simulated Auto Actuation: Each refueling.

Flow Rate Test: After pump maintenance and every 3 months

( Pwnp Operability: Onta/ month l Motor-Operated Valve Once/ month ,

Logic System Functional Test: Once/ Refuel l

In addition, current Technical Specification require the testing of I the LPCI mode of RHR, both core spray systenis, the automatic pressure relier l subsystem and RCIC system when HPCI is determined to be inoperable. The l proposed change to the HPCI testing requirements are as follows:

Valve Position: Every 31 days Flow Rate Test: Every 92 days Flow Rate Test @ Low and High Pressure During startup following j a refuel outage or an outage in which work was performed th t directly affects HPCI system operability. p Simulated Auto Actuation: Fach refuel outage Logic System Functional Test: Each refuel outage i

Testing of systems immediately following the declaration of an l Inoperable HPCI system has been deleted. ,

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The proposed change to Surveillance Requirement 4.5.C.1 will detail )

HPCI testing requirements in the HPCI Section of Specification 4.5 rather than j reference to the Core Spray and LPCI subsystem testing in Section 4.5.A.1. I The proposed changes to HPCI pump flow rate testing will add a pump flow rate i test which is performed at low reactor steam pressure during startup following ]

h refueling outage or an outage in which HPCI was performed that directly affected system operability. The present HPCI flow rate test criteria does not clearly specify a single test pressure. Present testing methods allow acceptance criteria tu ne met if one point on the pump curve is met against a system head pressure corresponding to a reactor vessel pressure of 1150 psig j to 150 psig. STS and later BWR industry is to perform two (2) flow rate tests !

for HPCI, i.e., one every 92 days and another under certain startup conditions. )

The flow test to be performed at least once per 92 days will demonstrate pump I operability by meeting ECCS design flow requirements when stemn is being supplied to the turbine at rated reactor pressure. This test requirement will also satisfy the testing provisions of the Inservice Testing Program.

The flow rate tests to be performed during startup following a refueling outage or an outage in which work was performed that directly affects HPCI system operability, involve testing at low reactor pressure (250 to 325 psig) followed by a test at rated reactor pressure. This testing l combination will demonstrate ECCS design flow and system performance prior to J 4

continuing the reactor startup. For the low pressure test, the 325 psig limit for testing is selected to allow the plant to be stable and to conform with t.he reactor pressure corresponding to the reactor injection valve permissive of the low pressure ECCS systems. The permissive for opening of the reactor injection valves for the low pressure ECCS systems is set at 325 psig. In order for the plant to be stabilized for testing, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed to perform testing once reactor steam pressure is adequate. The manufacturer of t.he HPCI turbine, General Electric, recommends additional testing of the system to demonstrate operability of the turbine overspeed trip. This overspeed trip test is performed approximately once per 18 months and involves disconnecting the HPCI pump and turbine and therefore the HPCI system is declared Lioperable during the test period. After the overspeed test completion, the system flow test is performed. The performance of both of theco tests in series will take longer than the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months proposed to allow performance of the flow test by itself'and thus 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is proposed to be allowed to perform these tests, i.e., overspeed trip test and system flow test, in series prior to exceeding 325 psig.

The proposed chsnges to the Surveillance Requirement 4.5.C.1 delete the monthly pump surveillance and changes the monthly valve operability checks to monthly valve lineup checks. The quarterly pwtp flow tests performed in accordhuce with Inservi'ce Testing Program are sufficient to demonstrate pump operability and justifjes the deletion of the present monthly pump surveli-lance. The present monthly valve operability checks can also be deleted since valves are .ncluded and tested in accordance with the Quad Cities Inservice Testing Program. The monthly valve operability check in made on the position l of each manual, power operated or automatic valve, in the flow path that is

, not locked, sealed or otherwise secured in position. These proposed changes l

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, . reflect operating practices at later BWR plants and since the Quad Cities ECCS systems are similar to those at later plants, the proposed changes are ,

justified and should be implemented. l The proposed change will delete present Surveillance Requirement 4.5.C.2 which requires, with HPCI inoperable, testing of the LPCI mode of RHR, both core spray subsystems, the automatic pressure relief subsystem and the i RCIC system. The present testing requirements for ECCS are very conservative since, at the time, there was a lack of plant operating history and a lack of sufficient equipment failure data base to choose other testing methods. Since l the initini development of the Quad Cities Units 1 and 2 Technical l Specifications, plant operating experience has demonstrated that multiple l testing of other ECCS systems when one system is inoperable, is not necessary ]

to provide adequate assurance of system operability. The systems operability is verified by reviewing records to ensure that valve and electrical lineups ,

and instrumentation requirements have not been changed since the last time that the system was demonstrated to be operable. This description is in the y surveillance bases. More recent BWR Technical Specifications accept system operability based on past satisf act3ry performance of monthly, quarterly, refueling interval, post maintenance and other specified performance tests without requiring additional testing when another system is inoperable.

The purpose of this change is to remove excessive system testing requirements

'while maintaining adequate assurance of system operability when needed for accident mitigation. One concern with equipment failures is common mode failure affecting the same parts in other system. Engineering evaluation for common mode failure is more effective than running systems and trying to find another failure of the same part. Once the potential for common mode failure has been identified, system operability is evaluated and potentially defective parts are replaced.

EflC_DEEBADILIII Current Technical Specifications require that the RCIC system shall l be operable whenever the reactor pressure is greater than 150 osig, irradiated fuel in the vessel and prior to startup from a cold condition. If the requirements cannot be met, an orderly shutdown is required and pressure shall be reduced to 90 psig. The proposed Technical Specification LCO requires that the RCIC system shall be greater than 150 psig and fuel is in the vessel. The reactor shutdown pressure has been increased to 150 psig.

The proposed change deletes the requirement for RCIC operability prior to reactor startup. The RCIC systems cannot be considered operable until reactor pressure'is adequate for system operation; therefore, RCIC cannot be operable prior to reactor startup from a cold condition. This change is considered to be administrative in nature and is being made to clarify current requirements.

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.The proposed change from " irradiated fuel" to " fuel" in the reactor vessel for RCIC operability is considered to be more conservative and administrative in nature.

The change to increase the reactor shutdown pressure is proposed in order to be consistent with the operability pressure requirement.

RCIc OUT OF SERYlCE TIME _ ALLOWANCE Current Technica] Specification' require that from and after the date.

the RCIC subsystem is made or found to be inoperable, continued reactor i

operation is permitted for 7 days. The proposed change creates a new 3.5.E.2 which describes actions to be taken during a startup from a refuel outage or an outage in which work was performed that directly affected RCIC operability.

The old 3.5.E.2 has been renumbered as 3.4.E.3 and is applicable for the ,

conditions other than described in Section 3.5.E.2.' The allowed out of service time in the proposed 3.5.E.3 has been extended from 7 days _14 days.

The proposed Section 3.5.E.2 was developed to clearly establish.the-requirements during a reactor startup from a refuel outage.or an outage in-which work was performed that directly affected RCIC operability. .The new

' Specification describes the limitations of the unit startup under these

conditions and require the implementation of Specification 3.5.E.4 in the i

event testing requirements are not met.

l 'l The proposed out of service period for the RCIC systen e from 7 days to 14 days adopts the philosophy of later BWR operating plants at Quad Cities for the RCIC systems. The proposed period reflects the availability of" low and high pressure core cooling systems for post accident mitigation functions.

A sta'.ement is proposed to the new Specification 3.5.E.3 (current Specification 3.5.E.2) to indicate that the specification is'not applicable l

during reactor startup from a refuel outage or an. outage in which work was l

periormed that directly affected RCIC operability. The actions required i

during these conditions are addressed under the newly proposed Specification 3.5.E.2. Separation of the conditions provide clarification to the required actions in the event of an inoperable system. The proposed' revision includes-a statement that requires an orderly shutdown to commence if the Specification requirements are not met.

RCIC SURYILLLAliCE_REQUIREMERI Current Technical Specifications require RCIC testing to be performed as follows:

,- Simulated Auto Actuation: Each refueling l Flow Rate Test: After pump maintenance'and every 3 months Pump Operability: Once/ month Motor-Operated Valve 'Once/ month Logic System Functional Test: Once/ month l i_- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ - - - _ _ _ _

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In addition, current Technical Specification require the testing of the HPCI system when RCIC is determined to be inoperable. The proposed change to the HPCI testing requirements are as follows: l l

Valve Position: Every 31 days ,

Flow Rate Test: Every 92 days l Flow Rate Test 0 Low and High Pressures During startup following following a refuel outage or an outage in which work was performed that directly affects HPCI system operability.

Simulated Auto Actuation: Each refuel outage Logic System Functional Test: Each refuel outage Testing of systems immediately following the declaration of an Inoperable HPCI system has been deleted.

l The proposed change to Surveillance Requirement 4.5.E.1 for RCIC are similar to those for HPCI. It should be noted that for RCIC, the only valves that are required to be tested por the Insorvice Testing Program are the conte innent isolation valves. Even though the RCIC pump is not required to be tested per the IST program, testing at least every 92 days is specified and i l has been demonstrated to be adequate at other BWR facilities with similar ;

I - system arrangements. The proposed flow test every 92 days for RCIC will l demonstrate operability of the entire system, up to the reactor injection J valve, including steam and water side valves, pump and turbine. The deletion l of Surveillance Requirement 4.5.E.2 is similar to changes proposed to HPCI l subsystem testing in that with RCIC inoperable, immediate and daily testing of I HPCI will not be required. )t RCI.C_DEERABILITY_JXEMPlIDH 1

l Current Technical Specifications discuss an exemption to allow l reactor startup with RCIC inoperable. The proposed change deletes the !

exemption since the period has expired and was a one-time exemption. l i

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ATIACIMDfL4 I 1

EYALUATION OF Sl@IFICANT HAZARDS CONSIDERATION i

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As described in the Description of Proposed Amendment Request, the l proposed changes involve updating the HPCI and the RCIC system requirements to I reflect later operating BWR plants' requirements, administrative changes, f changes in operability requirements to reflect HPCI design and to provide ,

I consistency in RCIC system requirements for operation and shutdown. These changes have been reviewed by Commonwealth Edison and we believe that they do not present a Significant Hazards Consideration. The basis for our determination is documented as follows:

l BASI s loa._HOEGtilflCANLIWARRS_CONSIDKEAT10H I

Commonwealth Edison has evaluated this proposed amendment and l determined that it involves no significant hazards consideration. In )

accordance with the criteria of 10 CFR 50.92(c) the proposed amendment does f not:

1. The proposed change does not involve a significant increase in the ;

probability or consequences of an accident previously evaluated. )

i The proposed amendment requires HPCI to be operable at greater than 150 ;

psig which is in conformance to design requirements and allows a 175 psi l overlap with the low pressure core cooling subsystems injection capabill-ties of approximately 325 psig. The deletion of the requirement for HPCI i and RCIC to be operable prior to reactor startup from a cold shutdown 1 provides clarification of intent until the reactor is producing steam at !

a pressure sufficient to provide water injection to the reactor. This clarification of intent does not reduce the availability of either the l HPCI or the RCIC systems when needed to perform their design function. j The proposed change from 90 to 150 psig for RCIC shutdown requirements is made to provide consistency with the reactor pressure of 150 psig l presently allowed in the RCIC operability requirements. The change for j both HPCI and RCIC in the allowed out of service time from 7 to 14 days, {

reflects an adoption of later BWR operating plant requirements at Quad l Cities for these systems. The 14 day out of service period reflects the {

low probability of the need for the systems and also reflects the l availability of high and low pressure. core cooling systems for post l accident mitigation functions. The deletion of the term irradiated from l the system operability requirements is conservative and does not reduce j system availability. j l

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l Proposed changes in testing requirements for HPCI and RCIC include l deletion of the testing of other core cooling systems when HPCI or RCIC l 1s inoperable. The present testing methods represent requirements beyond those necessary to adequately assure that remaining core cooling systems cre operable and capable of performing their design intent. The proposed deletion of this multiple system testing requirement will bring Quad Cities Units 1 and 2 in line with current DWR plant testing requirements.

The remaining changes to HPCI and RCIC requirements involve inclusion of Inservice Testing Program requirements where applicable and Standard Plant testing guidelines. These changes include deletion of monthly pump and valve operability tests but also include addition of monthly valve lineup checks and a new pump flow test to be conducted under certain startup conditions. The changes to the testing requirements will enhance determination of system operability by providing both a low and high pressure demonstration of pwnp performance. The quarterly pump performance tests have been demonstrated at later plants to provide assurance of system operability and thus the present monthly pump operability test can be deleted. The proposed monthly valve lineup checks have also been shown through use at other facilities to provide assurance ol system alignment and thus the monthly valve operability l

checks can be deleted. The Quad Cities Inservice Testing Program also l provides assurance of valve operability and pump performance were )

applicable. Flow rate testing of HPCI and RCIC is performed prior to exceeding 325 psig following a refueling outage or an outage in which work was performed that directly affects system operability. Selection ;

of the 325 psig limit for testing ensures stable reactor conditions during the test.

The deletion of the one time exception in the RCIC LCO fer Quad Cities Unit 1 is strictly an a&ninistrative change and does not af fect any accident analysis.

The proposed changes do not affect eny accident preaursors and, therefore, do not increase the probability of an accident previously evaluated. The changes in HPCI and RCIC operability requirements reflect system design, assure system operability when required, and provide sufficient overlap with low pressure core cooling systems. The changes j in testing requirements represent deletion of outdated requirements while i implem,nting provisions that will provide assurance of system operability. }

Therefore, the changes do not involve a significant increase in the i consequences of an accident previously evaluated.

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2. The proposed change does not create the possibility of a new or different i kind of accident from any accident previously evaluated.

The proposed changes do not modify HPCI or RCIC design or reduce the j capability of these systems to perform their design intent. The proposed j changes in testing implement the provisions of the Inservice Testing !

Program where applicable in these Technical Specifications and follow l proven implementation at other operating BWR plants. Even though the te. sting intervals are relaxed in some places, this relaxation has been i deinonstrated at other f acilities, with similar systems to those at Quad l Cities Units 1 and 2, to provide adequate demonstration of component and j system operability. !

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, , 1 L i1 Since liPCI and RCIC system design basis are not changed by the proposed changes, there is no possibility of a new or different kind of accident )

.from any previously evaluated. .

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3. The proposed change does not involve a significant reduction'in the margin of safety.

The proposed snendment will not significantly reduce the availability of HPCI or RCIC when required to mitigate accident conditions. Excessive test /ng of systems and components can reduce rather than increase reliability. An acceptable level of testing to demonstrate operability currently being used at later BWR plants does not include multiple testing of other systems when HPCI or RCIC ic inoperable. The testing )

that will, remain in the Technical Specifications provides adequate j assurance of system performance. Changes to HPCI and RCIC system testing requirements include adoption of proven testing methods at other plants, inclusion of applicable IST pregram requirements, and inclusion of plant specific testing requirements. l

-1 Changes to the operability requirements for HPCI and RCIC are made to l recognize design parameters and to provide consistency in operability and shutdown provisions. Actual system operating overlap with the low pressure core cooling systems has not changed since actual system design flow and pressure ability has not been modified. Adoption of the 14 day ,

allowed out of service period does not significantly affect the accident i mitigation function of the overall core cooling network.

The proposed changes follow sinillar provisions that are implemented at DWR plants with systems like thoee at Quad Cities Units 1 and 2. Since the proposed changes will help to asrure availability of the HPCI and RCIC systems when required by acc10ent analysis, these changes do not involve a significant reduction in the margin of safety.

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