View source for SVP-99-128, Application for Amends to Licenses DPR-29 & DPR-30,changing TS Section 3/4.3.C, Reactivity Control - Control Rod Operability

{{Adams
| number = ML20209C284
| issue date = 06/29/1999
| title = Application for Amends to Licenses DPR-29 & DPR-30,changing TS Section 3/4.3.C, Reactivity Control - Control Rod Operability
| author name = Dimmette J
| author affiliation = COMMONWEALTH EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000254, 05000265
| license number = 
| contact person = 
| document report number = SVP-99-128, NUDOCS 9907090238
| package number = ML20209C289
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 6
| project = 
| stage = Request
}}

=Text=
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June 29,1999                                                                                   !
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SVP-99-128                                                                                     l U.S. Nuclear Regulatory Commission                                                             i ATTN: Document Control Desk Washington, D C 20555 Quad Cities Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

==Subject:==
Technical Specification Change Request Technical Specification Section 3 /4.3, " Reactivity Control - Control Rod Operability"

==Reference:==
(1) Letter from P.W. O' Conner (U. S. NRC) to C. Randy Hutchinson (Entergy Operations), dated February 16,1995.
In accordance with 10 CFR 50.90 we request a change to Technical Specifications (TS), of facility License Nos. DPR-29 and DPR-30, for the Quad Cities Nuclear Power Station, Units 1 and 2 respectively. The proposed change is to TS Section 3/4.3.C,            i
                   " Reactivity Control- Control Rod Operability."                                                j 1
The proposed amendment revises the requirement for control rod testing to increase             l the " notch testing" surveillance interval of TS Surveillance Requirement 4.3.C.1.a for partially withdrawn control rods from once per 7 days to once per 31 days. The current weekly surveillance imposes an undue burden on operating personnel to perform unnecessary control rod manipulations with no increase in the margin of safety. This          i change is consistent with the improved Standard Technical Specifications as                   I documented in NUREG-1433, Revision 1, " Standard Technical Specifications, General Electric Plants, BWR/4," and has previously been approved for the Grand Gulf Nuclear    j Power Station per the referenced letter.
Comed requests approval of this amendment by December 10,1999.                                l 0
0 9907090238 990629 PDR   ADOCK 05000254 P                        PDR l
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Juns 25,1999 U.S. Nucinr Regulatory Commission Page 2 This request is subdivided as follows:                                                      1
: 1. Attachment A gives a description and safety analysis of the proposed changes,
: 2. Attachment B includes the marked-up TS pages with the requested changes              {
indicated,
: 3. Attachment C provides information supporting a no significant hazard finding in accordance with 10 CFR 50.92(c).
: 4. Attachment D provideh information supporting an Environmental Assessment.
These proposed changes have been reviewed by the Plant Operations Review Committee and the Nuclear Safety Review Board in accordance with the Quality Assurance Program.
Comed is notifying the State of Illinois of this application request for changes to the TS  (
by transmitting a copy of this letter and its attachments to the designated State Official.
Should you have any questions concerning his letter, please contact Mr. W. J. Beck at (309) 654-2241, extension 3100.
Res      tfully,
                                         ~
M"A '    ,/
Joel P. Dimmette, Jr.
Site Vice President Quad Cities Nuclear Power Station Attachments                                                                                 1
             - Affidavit Attachment A: Description and Safety Analysis for Proposed Changes Attachment B: Marked-Up Pages for Proposed Changes Attachment C: Information Supporting No Significant Hazard Findings Attachment D: Information Supporting An Environmental Assessment cc:    Regional Administrator-NRC Region lll NRC Senior Resident inspector- Quad Cities Nuclear Power Station l
L

p                                                                                                                                          1 i
1 1
                 ' STATE OF ILLINOIS                                                                       )
COUNTY OF ROCK ISLAND                                                                   )
IN THE MATTER OF                                                                        )
CSMMONWEALTH EDISON (COMED) COMPANY                                                     )      Docket Numbers QUAD CITIES NUCLEAR POWER STATION UNITS 1 and 2                                         )      STN 50-254 and STN 50-265

==SUBJECT:==
Technical Specification Change Request Technical Specification Section 3 /4.3, " Reactivity Control - Control Rod Operability" AFFIDAVIT                                                       l
                                                                                                                                            )
4 I affirm that the content of this transmittal is true and correct to the best of my knowledge, information and belief.
Yhl b11AvdV Joel P. Diinmette, Jr.'
Site Vice President I
Subscribed and sworn to before me, a Notary Public in and for the State above named, this              29          day of 1mo                      .19 9 #    .
ww e        Ihnwdbt OFFICIAL SEAL.
I Notary Public LYNNE F.HAME. TON Notary Public, State ofImnois My Commiselon 16pires 01/2503 C_____.____.___

ATTACHMENT A, Pr: posed Chrnge is Technicti Specificiti:n fer Quzd Citica Nuclear Pow:r Stati n Unita 1 End 2, P:ge 1 of 3 DESCRIPTION AND SAFETY ANALYSIS                                   l FOR PROPOSED CHANGES A. 

==SUMMARY==
OF PROPOSED CHANGES in accordance with 10 CFR 50.90, Commonwealth Edison (Comed) Company proposes a change to Appendix A, Technical Specifications (TS), Facility Operating Licenses DPR 29 and DPR-30. The application for amendment requests a change to Technical Specifications Section 3/4.3.C, Reactivity Control- Control Rod Operability.
The request revises Surveillance Requirement 3 /4.3.C.1.a to increase the surveillance interval for partially withdrawn control rods from once per 7 days to once per 31 days.
A note is also added clarifying the surveillance is not required to be performed until 7 days (after fully withdrawn) and 31 days (for partially withdrawn) after the control rod is withdrawn and thermal power is greatar than the low power setpoint of the Rod Worth Minimizer (RWM). Fully withdrawn contrd rods will continue to be tested once per 7 days. This change is consistent with the improved Standard Technical Specifications         1 as documented in NUREG-1433, Revision 1, and as previously approved for the Grand           '
Gulf Nuclear Power Station per the referenced letter.
The proposed changes are described in detail in Section E of this Attachment. The marked up Technical Specification (TS) pages are shown in Attachment B.
B. DESCRIPTION OF THE CURRENT REQUIREMENTS TS Section 4.3.C.1.a provides the surveillance requirements for the Control Rod Drive
        ~ (CRD) exercising. Current TS 4.3.C.1.a specifies:
4.3.C.1.         When above the low power setpoint of the RWM, all withdrawn control rods not required to have their control valves disarmed electrically or hydraulically shall be demonstrated OPERABLE by moving each control rod at least one notch:
: a.      At least once per 7 days.
C. BASES FOR THE CURRENT REQUIREMENT Control rod insertion capability is demonstrated by inserting each control rod at least one notch and observing that the control rod moves. The control rod may then be returned to its original position. This ensures the control rod is not stuck and is free to insert on a scram signal. These Surveillance's are not required when THERMAL POWER is less t" ~ n or equal to the low power setpoint of the RWM, since the notch         i insertions may not se compatible with the requirements of the RWM. The 7 day                I Frequency of SR 4.3.C.1.a is based on operating experience related to the changes in CRD performance and the ease of performing notch testing for control rods. At any time, if a control rod is immovable, a determination of that control rod's trippability     j (OPERABILITY) must be made and appropriate action taken.

l i
i ATTACHMENT A, Pr: posed Ch:nge to Techni:11 Specific tian far Quid Citica Nuclear Pow;r Stiti:n Units 1 and 2, Page 2 of 3 D. NEED FOR REVISION OF THE REQUIREMENT                                                    j The current TS Requirement places undue burden upon plant operation without an increase in the margin of safety. The current surveillance requirement is restrictive in   j requiring a notch exercise of all rods every 7 days. The proposed reduction in control     '
rod manipulations decreases potential power changes and is padent core management by reducing the frequency of having to cycle control rods from their intermediate positions.
l t
This proposed change is consistent with the Improved Standard Technical                    l Specifications (ISTS) NUREG-1433, Revision 1.
l E. DESCRIPTION OF THE PROPOSED CHANGES The requested change will revise the frequency of notch exercising for partially withdrawn control rods from 7 days to 31 days. A note is also added to change wording to be consistent with ISTS which clarifies the intent of the Surveillance.
F. SAFETY ANALYSIS OF THE PROPOSED CHANGES The current Quad Cities Nuclear Power Station TS for control rod operability (TS 3/4.3) assures that the minimum Shutdown Margin is maintained, the control rod scram times are consistent with those used in the accident and transient analysis and the potential effects of the rod drop accident and rod withdrawal error are limited. The surveillance requirements for the control rod drives include verifying that each withdrawn control rod is capable of moving by exercising the CRD at least one notch once per 7 days when operating above the low power setpoint of the RWM. This surveillance (3.4.3.C.1.a) provides a means of identifying control rods that are immovable as a result of excessive friction or mechanical interferences.
The proposed amendment increases the surveillance interval for partially withdrawn control rods from once per 7 days to once per 31 days. This is consistent with the ISTS Nureg-1433, Revision 1. In addition, Industry Data on control rod drive reliability indicates an extremely low failure rate for failures detected during the weekly serveillance testing. Reference (1).

ATTACHMENT A, Pr: posed Ch:nge 13 Technic 1 Specific:ti:n f:r Quid Citi;a Nuclear Power Station Units 1 and 2, Page 3 of 3 Quad Cities Nuclear Power Station experience with control rod drive mechanisms also indicates a high degree of reliability. A review of operating performance over the last 5 years for each unit has not identified any problems due to a control rod being immovable due to excessive friction or mechanical interference                              j Therefore, based on actual Control Rod Drive operating experience, the proposed surveillance interval is adequate to maintain a high level of safety and reliability.
G. IMPACT ON PREVIOUS SUBMITTALS 1
Comed has reviewed the proposed Operating License Amendment request regarding impact on any previous submittals, and has determined that there is no impact on any outstanding previous submittals.
H. GCHEDULE REQUIREMENTS Comed requests approval of this amendment by December 10,1999.
: 1. REFERENCES 1
NUREG/CR-5699, Aging and Service Wear of Control Rod Drive Mechanisms for BWR               l Nuclear Power Plants. Draft issued August 1991.                                           -
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