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Quad Cities Nuclear Power Station Technical Requirements Manual (TRM) October 2017 Quad Cities Nuclear Power Station, Unit 1 and 2 Renewed Facility Operating License Nos. DPR-29 (Unit 1) and DPR-30 (Unit 2) NRC Docket Nos. STN 50-254 (Unit 1) and 50-265 (Unit 2)
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TRM Appendix C SFDP Quad Cities 1 & 2 C-1 Revision 0 TABLE OF CONTENTS
A. PURPOSE
............................................................................................................................2 B. REFERENCES
....................................................................................................................2 C. DEFINITIONS
.....................................................................................................................2 D. LIMITATIONS
....................................................................................................................3
E. PROCEDURE
......................................................................................................................4 E.1 LCO 3.0.6 REQUIREMENTS.......................................................................................4 E.2 T.S. 5.5.11, Safety Function Determination Program (SFDP) Requirements.............6 E.3 Program Implementation................................................................................................8
FIGURE 1 LOSF Evaluation Flow Chart.......................................................................................11
ATTACHMENTS 1 Loss Of Safety Function Evaluation............................................................................13 2 Supported System (s) Completion Time Extensions..................................................19 3 SFDP Tracking Worksheet...........................................................................................26
TABLE 1 Cross Train Check Guidance........................................................................................30
TRM Appendix C SFDP Quad Cities 1 & 2 C-2 Revision 0 A. PURPOSE A.1 Objective
The purpose of the SFDP is to enus re that when Technical Specification LCO 3.0.6 is used to preclude performing the Conditions and Actions for inoperable SUPPORTED SYSTEMS:
- A Loss of Safety Function does not go undetected,
- The plant will be placed in a safe condition if a Loss of Safety Function is determined to exist, and
- A supported SYSTEM(S) Completion Time will not be inappropriately extended.
B. REFERENCES
B.1 Technical Specification (TS) 3.0.6.
B.2 TS 5.5.11, "Safety Function Determination Program (SFDP)"
C. DEFINITIONS
C.1 SAFETY FUNCTION
-
An accident mitigation feature required by NRC regulation, plant design or Technical Specifications normally composed of two trains of SUPPORT and SUPPORTED equipment.
C.2 LOSS OF SAFETY FUNCTION (LOSF)
-
A LOSF exists when, assuming no concurrent single failure and assuming no concurrent loss of offsite power or loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. (SEE ATTACHMENT 1.0)
C.3 SUPPORT SYSTEM - A SYSTEM(S) that is needed by another TS LCO required SYSTEM(S) to perform a safety function.
TRM Appendix C SFDP Quad Cities 1 & 2 C-3 Revision 0 C.4 SUPPORTED SYSTEM
- A SYSTEM, required by the TS, which requires a SUPPORT SYSTEM to ensure its safety function can be performed. Process parameters or operating limits do not comprise SUPPORTED SYSTEM(S) for the purposes of implementing TS LCO 3.0.6.
C.5 MAXIMUM OUT OF SERVICE TIME -
A SUPPORTED SYSTEM(S) made inoperable by the SUPPORT SYSTEM(S) inoperability shall be re stored to OPERABLE status within the Maximum Out Of Service Time (MOST). The MOST is the Completion Time specified in the Tec hnical Specifications for restoring the first inoperable SUPPORT SYSTEM(S) to OPERABLE status plus the time specified in the TS for restor ing the SUPPORTED SYSTEM(S) to OPERABLE status. (SEE ATTACHMENT 2 - Completion Time
Extensions )
The inoperability of the SUPPORTED SYSTEM(S) must only be directly attributed to its associated SUPPORT SYSTEM(S) bei ng inoperable and the SUPPORT SYSTEM(S) Required Actions not specifically requiring
entry into the SUPPORTED SYST EM(S) Conditions and Required Actions.
D. LIMITATIONS
D.1 Reporting Requirements will be done in accordance with the Reportability Manual.
D.2 Changes to this Program shall be performed in accordance with the TRM Change Control Program.
D.3 The Shift Manager is responsible for implementing the Safety Function Determination Program.
TRM Appendix C SFDP Quad Cities 1 & 2 C-4 Revision 0
E. PROCEDURE
E.1 LCO 3.0.6 REQUIREMENTS
E.1.1 TS LCO 3.0.2 states that upon discovery of a failure to meet an TS LCO, the Required Actions of the associated Conditions shall be met, except as provided in TS LCO 3.0.5 and TS LCO 3.0.6.
E.1.2 TS LCO 3.0.6 provides an exception to TS LCO 3.0.2 for SUPPORT SYSTEM(S) by not requiring the Conditions and Required Actions for the SUPPORTED SYSTEM(S) to be performed when the failure to meet an TS LCO is solely due to a SUPPORT SYSTEM(S) LCO not being met. In this situation, although the SUPPORTED SYSTEM(S) is determined to be inoperable as defined in the Technical Specifications, LCO 3.0.6 requires only the ACTIONS of the SUPPORT SYSTEM(S) to be performed. The Conditions and Required Actions for the SUPPORTED SYSTEM(S) are not required to be performed (i.e., cascading to the SUPPORTED SYSTEM(S)) per TS LCO 3.0.6.
E.1.3 There are two types of SUPPORT SYSTEM(S) that must be considered when implementing TS LCO 3.0.6:
- SUPPORT SYSTEM(S) specifica lly addressed in Technical Specifications, and
- SUPPORT SYSTEM(S) that are not specifically addressed in Technical Specifications NOTE It may be necessary to perform OPERABILITY Determinations in accordance with Procedure RS-AA-105 in order to determine SUPPORTED SYSTEMS made Inoperable by Inoperable SUPPORT SYSTEMS.
If required SUPPORT SYSTEM(S) is addressed in the Technical Specifications, then only the SU PPORT SYSTEM(S) Conditions and Actions must be entered per TS LCO 3.0.6 (i.e., "cascading" to the SUPPORTED SYSTEM(S) is not required).
TRM Appendix C SFDP Quad Cities 1 & 2 C-5 Revision 0 If required SUPPORT SYSTEM(S) is NOT addressed in the Technical Specifications, then impact of the SUPPORT SYSTEM(S) inoperability must be evaluated with respect to any SUPPORTED SYSTEM(S) that is addressed in Technical Specifications.
E.1.4 A single component inoperability may result in multiple inoperabilities within a single train and affect multiple TS LCOs. TS LCO 3.0.6 limits the amount of "cascading" Actions that are required when an inoperable SYSTEM(S) renders a SUPPORTED SYSTEM(S) inoperable.
E.1.5 Any SUPPORT SYSTEM(S) inoperability must be evaluated with respect to the existing plant conditions to ensure that a Loss of Safety Function (LOSF) does not exist.
Example: The loss of Residual Heat Removal Service Water (RHRSW) Pump to one RHRSW heat exchanger. If the heat exchanger bypass valve was found stuck open in the opposite subsystem, a LOSF will exist
following a loss-of-coolant-accident and this plant configuration must be evaluated.
E.1.6 When exception of TS LCO 3.0.6 is u tilized, evaluations are required in accordance with TS 5.5.11, "Safety Function Determination Program (SFDP)".
E.1.7 If LOSF is determined to exist by this Program, the appropriate Conditions and Required Actions of the TS LCO in which the LOSF exists are required to be entered.
E.1.8 When SUPPORT SYSTEM(S) Required Action directs a SUPPORTED SYSTEM(S) to be declared inoperable or directs entry into Conditions and Required Actions for a SUPPORTED SYSTEM(S), the applicable Conditions and Required Actions shall be entered in accordance with TS LCO 3.0.2.
E.1.9 It should be noted that for cas es in which the inoperable SUPPORT SYSTEM(S) is addressed in Technical Specifications, "cascading" Conditions and Required Actions may still be performed in lieu of entry
into TS LCO 3.0.6.
TRM Appendix C SFDP Quad Cities 1 & 2 C-6 Revision 0 E.2 T.S. 5.5.11, SAFETY FUNCTION DETERMINATION PROGRAM (SFDP) REQUIREMENTS NOTE If failure of a TS required SUPPORT SYSTEM(S) results in the inoperability of a SYSTEM(S) outside of the TS, and that SYSTEM(S) is subsequently relied upon by a SUPPORTED SYSTEM(S) to remain OPERABLE, then TS LCO 3.0.6 could apply and only the SUPPORT SYSTEM(S) Required Actions would be entered.
E.2.1 When TS LCO 3.0.6 is used as an exception to TS LCO 3.0.2, an evaluation is required to ensure a LOSF is detected and appropriate actions are taken.
E.2.2 Therefore, the SFDP requires:
E.2.2.1 Cross train checks to ensure a LOSF does not go undetected;
- Since "cascading" the Conditions and Required Actions of a Specification are not required when applying TS LCO 3.0.6, a possibility exists that unr elated concurrent failures of more than one SYSTEM(S) could result in the complete loss of both trains of a SUPPORTED SYSTEM(S). Therefore, upon a failure to meet two or more LCOs during the same time period, an evaluation shall be conducted to determine if a LOSF exists. Generally, this is done by confirming that the remaining required redundant SYSTEM(S) are OPERABLE. ( Per ATTACHMENT 1 and TABLE 1) If a LOSF does exist, the SFDP directs that the appropriate actions be taken.
E.2.2.2 Placing the plant in a safe condition if a LOSF is detected;
- If LOSF is determined to exist by this Program, the appropriate Conditions and Required Actions of the LCO in which the LOSF exists are required to be entered per step E.3.4.
TRM Appendix C SFDP Quad Cities 1 & 2 C-7 Revision 0 E.2.2.3 Controls on extending completion times on inoperable supported SYSTEM(S);
- MOST is determined per Attachment 2.
E.2.2.4 Appropriate limitations and remedial or compensatory actions to be taken as a result of the support SYSTEM(S) inoperability.
TRM Appendix C SFDP Quad Cities 1 & 2 C-8 Revision 0 E.3 PROGRAM IMPLEMENTATION Performing steps E.3.1 thru E.3.7 and / or use of the Flowchart (Figure 1) will implement the requirements of the SFDP.
E.3.1 Does the degraded SYSTEM(S) render a TS required SYSTEM(S) inoperable?
E.3.1.1 If NO, then no further evaluation is necessary.
E.3.1.2 If YES, then evaluate this inoperabilities impact on any current SFDs and document on worksheet.
E.3.2 Is the inoperable SYSTEM(S) also a SUPPORT SYSTEM(S)?
E.3.2.1 If NO, then perform Conditions and Require d Actions for the inoperable SYSTEM(S).
E.3.2.2 If YES, then evaluate all Conditions and Required Actions of any SUPPORTED SYSTEM(S) that are rendered inoperable as a result of this TS SUPPORT SYSTEM Inoperability.
E.3.3 Does the Inoperable SUPPORT SYSTEM(S) Specification Conditions and Required Actions direct either the Immediate Declaration of Inoperability of SUPPORTED SYSTEM(S) or performance of any SUPPORTED SYSTEM(S) Required Action(s)?
E.3.3.1 If YES, then enter the TS Condition for the SUPPORTED SYSTEM(S) as directed and perform the Required Actions.
E.3.3.2 If NO, then: EITHER
- PERFORM both the SUPPORT and the SUPPORTED SYSTEM(S) Required Actions.
TRM Appendix C SFDP Quad Cities 1 & 2 C-9 Revision 0 OR
- PERFORM SUPPORT SYSTEM(S) Required Actions, And
- PERFORM a LOSF Evaluation for ALL inoperable SUPPORT and SUPPORTED SYSTEM(S) , per ATTACHMENT 1 and Table 1.
E.3.4 If LOSF is determined to exist, then perform the appropriate Conditions and Required Actions as determined from using the following guidance.
E.3.4.1 SINGLE SUPPORT SYSTEM INOPERABILITY-
When LOSF is solely due to a single T.S. SUPPORT SYSTEM ( e.g., loss of a pump suction source due to low tank level ) the appropriate LCO is the LCO for the SUPPORT SYSTEM. The Actions for the SUPPORT
SYSTEM LCO adequately address the inoperabilities of that system without reliance upon the Actions of the SUPPORTED SYSTEM.
E.3.4.2 MULTIPLE SUPPORT SYSTEM INOPERABILITY-
When LOSF is due to multiple T.S. SUPPORT SYSTEM inoperabilities, the appropriate LCO is the LCO for the SUPPORTED SYSTEMS.
(e.g. loss of minimum flow switch on Division 1 and the 'B' RHR Pump is inoperable. LOSF associated with ECCS may exist following a loss-of-coolant-accident and this plant configuration must be evaluated.)
E.3.5 If NO LOSF exists or LOSF is solely due to a single T.S. support system, then for all SUPPORTED SYSTEM(S) which are rendered inoperable:
E.3.5.1 Invoke TS LCO 3.0.6 to defer entry into the Conditions and Required Actions associated with the inoperable SUPPORTED SYSTEM(S) by the following:
E.3.5.1.1 Calculate the MOST for the inoperable SUPPORTED SYSTEM(S) using ATTACHMENT 2.
TRM Appendix C SFDP Quad Cities 1 & 2 C-10 Revision 0 E.3.5.1.2 Complete the SFDP Worksheet per Attachment 3.0.
- When filling out the SFD Worksheet it is only necessary to enter names of those SUPPORTED SYSTEMS that are made Inoperable by the Inoperable SUPPORT SYSTEM. It is not necessary to identify either OPERABLE SUPPORTED SYSTEMS or SUPPORTED SYSTEMS that are not in the MODE OF
APPLICABILITY.
EXAMPLE: Assume the "C" LPCI Pump minimum flow switch is INOPERABLE which results in TS LCO 3.3.5.1 not being met while the Unit is in MODE 1. A review indicates that TS LCO 3.3.5.1 equipment supports systems governed by TS 3.5.1, TS 3.5.2, TS 3.8.1, and TS 3.8.2. Although TS 3.8.1 and TS 3.8.2 are supported by TS 3.3.5.1 ( the emergency DGs are started by a Injection Spray Logic signal) , it would not be necessary to list these supported LCOs because they are not made INOPERABLE by the INOPERABLE minimum flow switch. It is also not necessary to list TS 3.5.2 because this LCO is not applicable in MODE 1. TS LCO 3.5.1 is the only SUPPORTED SYSTEM made INOPERABLE by the minimum flow switch.
E.3.6 If SUPPORTED SYSTEM(S) is NOT restored to OPERABLE status (by restoring the SUPP ORT SYSTEM(S) and all associated SUPPORTED SYSTEM(S) to Operable status) within the MOST, the associated
Condition for the INOPERABLE SUPPORTED SYSTEM(S) Completion Time not being met shall be entere d and the Required Actions shall be performed.
E.3.7 The SFD may be closed when the INOPERABLE SUPPORT SYSTEM and SUPPORTED SYSTEM(S) on the SFDP TRACKING SHEET are restored to Operable Status. Enter the time/date when the SUPPORT SYSTEM as well as all SUPPORTED SYSTEM(S) are restored to Operable status, and sign the SFD Worksheet.
TRM Appendix C SFDP Quad Cities 1 & 2 C-11 Revision 0 Figure 1 LOSF Evaluation Flow Chart Is the InoperableSystem a SupportSystem?N oPerform Applicable Conditionsand Required Actions for theIdentified Inoperability YesDoes the InoperableSupport System Conditionsand Required Actions directeither: (1) ImmediateDeclaration of Inoperabilityof Supported System(s) or(2) Performance of anySupported System RequiredActions?Yes No(Step E.3.1)(Step E.3.2)(Step E.3.3)Does the degradedSYSTEM(S) rendera TS RequiredSystem Inoperable?No further evaluationis necessaryEvaluate this inoperabilities impact on any current SFDs and document on worksheet(s). Yes NoEvaluate InoperableSupported System(s)Conditions and RequiredActionsGo to Next Pa g ePerform Applicable Conditionsand Required Actions for theSupported System InoperabilityYesYes TRM Appendix C SFDP Quad Cities 1 & 2 C-12 Revision 0 Figure 1 (Continued)
LOSF Evaluation Flow Chart (1) Perform Support SystemConditions and RequiredActionsAND(2) Perform LOSF Evaluation(per ATTACHMENT 1 andTABLE 1)Yes NoLOSFExists?1.For Single Support SystemInoperability, Enter LCO,Conditions and Required Actions of the Support System(s)in which the LOSF exists.2.For Multiple Support SystemInoperability, Enter LCO, Condiitons and RequiredActions of the Supported System(s) in which the LOSFexists.1.Calculate SUPPORTEDSYSTEM(S) MOST (Per ATTACHMENT 2) 2.Complete the SFDP Worksheet (per Attachment 3.0
)YES NoEITHERPerform both Support& Supported SystemRequired Actions(Step E.3.3)(Step E.3.4)(Step E.3.6)(Step E.3.5)Supported SystemOPERABILITYrestored withinallowed completiontime?(Step E.3.7)From previous p a g eSFD may be closed when the Support System andSupported Systems are restored to o perable status.Enter associated Conditions andRequired Actions for theSupported System CompletionTime not being met No TRM Appendix C SFDP Quad Cities 1 & 2 C-13 Revision 0 ATTACHMENT 1 LOSS OF SAFETY FUNCTION EVALUATION A. Guidance for Safety Function Evaluation TS 5.5.11 states that a LOSF exists when, assuming no concurrent single failure, and assuming no concurrent loss of offsite power or loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a "graduated" approach may be taken for determining the "safety function" of the SUPPORTED SYSTEM(S). This approach, detailed below, is graduated from most to least conservative. Even if the least conservative method is used, the requirements of TS 5.5.11 will be met. In determining whether a LOSF has occurred, at least one of these methods must be used. Method 1: Redundant SUBSYSTEM(S)/Division/Train a. For this method, the safety function is assumed to be the SYSTEM(S) function as described in the TS BASES. Confirm the OPERABILITY of the corresponding redundant SUPPORTED SYSTEM(S). b. If one or more of the redundant SYSTEM(S) are found to be INOPERABLE, a LOSF may exist. The appropriate ACTIONS for a LOSF may be taken or alternatively, one of the following methods below may be used.
A redundant train evaluation used to identify a LOSF can be seen in the following three examples.
TRM Appendix C SFDP ATTACHMENT 1 (Continued) LOSS OF SAFETY FUNCTION EVALUATION Quad Cities 1 & 2 C-14 Revision 0 SUPPORT/SUPPORTED SYSTEM(S) DIAGRAM EXAMPLE 1 A LOSF may exist when a SUPPORT SYSTEM is INOPERABLE, and:
A required SYSTEM redundant to the SYSTEM(S) supported by the INOPERABLE SUPPORT SYSTEM is also INOPERABLE.
If SYSTEM 2 of Train A is INOPER ABLE, and SYSTEM 5 of Train B is INOPERABLE, a LOSF may exist in SUPPORTED SYSTEM(S) 5, 10, 11.
EXAMPLES TRAIN A TRAIN B
Note: Chart reads from left to right, i.e., SYSTEM 1 is a SUPPORT SYSTEM for SYSTEM(S) 2 through 15.
TRM Appendix C SFDP ATTACHMENT 1 (Continued) LOSS OF SAFETY FUNCTION EVALUATION Quad Cities 1 & 2 C-15 Revision 0 SUPPORT/SUPPORTED SYSTEM(S) DIAGRAM EXAMPLE 2 A LOSF may exist when a SUPPORT SYSTEM is INOPERABLE, and:
A required SYSTEM redundant to the SYSTEM(S) in turn supported by the INOPERABLE SUPPORTED SYSTEM(S) is also INOPERABLE.
If SYSTEM 2 of Train A is INOPERABLE, and SYSTEM 11 of Train B is INOPERABLE, a LOSF may exist in SYSTEM 11 which is in turn supported by SYSTEM 5.
EXAMPLES TRAIN A TRAIN B
Note: Chart reads from left to right, i.e., SYSTEM 1 is a SUPPORT SYSTEM for SYSTEM(S) 2 through 15.
TRM Appendix C SFDP ATTACHMENT 1 (Continued) LOSS OF SAFETY FUNCTION EVALUATION Quad Cities 1 & 2 C-16 Revision 0 SUPPORT/SUPPORTED SYSTEM(S) DIAGRAM EXAMPLE 3
A LOSF may exist when a SUPPORT SYSTEM is INOPERABLE, and:
A required SYSTEM redundant to the SU PPORT SYSTEM(S) for the SUPPORTED SYSTEM(S) (a) and (b) above is also INOPERABLE.
If SYSTEM 2 of Train A is INOPER ABLE, and SYSTEM 1 of Train B is INOPERABLE, a LOSF may exist in SYSTEM(S) 2, 4, 5, 8, 9, 10 and 11.
EXAMPLES TRAIN A TRAIN B
Note: Chart reads from left to right, i.e., SYSTEM 1 is a SUPPORT SYSTEM for SYSTEM(S) 2 through 15.
TRM Appendix C SFDP ATTACHMENT 1 (Continued) LOSS OF SAFETY FUNCTION EVALUATION Quad Cities 1 & 2 C-17 Revision 0 Method 2: TS LCO Function Method 2: TS LCO Function
- a. In certain cases, multiple SYSTEM(S) with diverse individual functions are specified under one TS LCO statement; i.e., in one Technical Specification. For these cases, the safety function may be considered to be broader than the individual SYSTEM(S) function - the safety function is the Technical Specification LCO function, not the SYSTEM(S) function (as described in Method 1 above).
- b. An example of this is TS 3.5.1, "ECCS-Operating," in which four different SYSTEM(S) are included. In this case, the function as stated in the Bases, "-to cool the core during a LOCA," may be the safety function to be considered in the SFDP.
- c. If a loss of TS LCO function is determined to exist, the appropriate Conditions and Required Actions for a LOSF may be taken or alternatively, the following method below may be used.
Method 3: Safety Analysis
In this approach, the function of the SYSTEM(S) described in the UFSAR accident analyses is considered to be the safety function. If the SYSTEM(S) in question is not credited in the accident analyses, or if the accident function it performs is intact, then no LOSF exists. However, if the SYSTEM(S) function is credited and is lost (i.e., the accident function it performs cannot be met), then the appropriate ACTIONS for a LOSF must be taken.
TRM Appendix C SFDP ATTACHMENT 1 (Continued) LOSS OF SAFETY FUNCTION EVALUATION Quad Cities 1 & 2 C-18 Revision 0 B. Loss of Safety Function (LOSF) Evaluation
Is there any INOPERABLE or degraded SUPPORT SYSTEM(S) or SUPPORTED SYSTEM(S) equipment on the opposite/redundant train that, when coupled with this INOPERABLE equipment, might result in a complete loss of a Tech Spec required safety function.
- 1. NO - No LOSF exists. No further evaluation is necessary.
- 2. YES - A LOSF may exist. Evaluate which of the following conditions apply:
- a. The SYSTEM(S) is part of an TS LCO with multiple SUBSYSTEM(S) and the TS LCO specified function is intact. No LOSF exists.
- b. The SYSTEM(S) will still perform its required safety function as defined in the UFSAR. No LOSF exists.
- c. A LOSF exists. Perform the Required Actions in which the LOSF exists for the specific Condition(s) that apply.
C. SUPPORTED SYSTEM LOSF
When a LOSF is determined to exist, and the SFDP requires entry into the appropriate Conditions and Required Actions of the LCO in which the LOSF exists, consideration must be given to the specific type of function affected.
- 1. SINGLE SUPPORT SYSTEM INOPERABILITY-
When a LOSF is solely due to a single T.S. SUPPORT SYSTEM ( e.g., loss of a pump suction source due to low tank level ) the appropriate LCO is the LCO for the SUPPORT SYSTEM. The Actions for the SUPPORT SYSTEM LCO
adequately address the in operabilities of that syst em without reliance upon the Actions of the SUPPORTED SYSTEM.
- 2. MULTIPLE SUPPORT SYSTEM INOPERABILITY-
When a LOSF is due to multiple T.S. SUPPORT SYSTEM inoperabilities, the appropriate LCO is the LCO for the SUPPORTED SYSTEMS.
TRM Appendix C SFDP Quad Cities 1 & 2 C-19 Revision 0 ATTACHMENT 2 SUPPORTED SYSTEM (S) CO MPLETION TIME EXTENSIONS BACKROUND The T.S. require declaring SUPPORTED SYSTEM(S) INOPERABLE if a SUPPORT SYSTEM(S) inoperability renders the SUPPORTED SYSTEM(S) incapable of performing its required function. However, the Conditions and Required Actions of the SUPPORTED SYSTEM(S) do not have to be entered (i.e., the Conditions and Required Actions are not entered) except as directed by the SUPPORT SYSTEM(S) Required Actions.
Consequently, it is possible to have SU PPORTED SYSTEM(S) I NOPERABLE for longer periods of time than their respective Completion Time would allow on their own. Per Technical Specifications 5.5.11, the SFDP must include measures to ensure that the SUPPORTED SYSTEM('S) Completion Times are not inappropriately extended.
The following two methods are provided for ensuring Completion Times are not inappropriately extended. METHOD 1 applies to SUPPORTED SYSTEM inoperabilities associated with a single SUPPORT SYSTEM inoperability. METHOD 2 is applicable to those SUPPORTED SYSTEM inoperabilities due to multiple SUPPORT SYSTEM inoperabilities.
METHOD 1 Single SUPPORT SYSTEM(S) INOPERABLE affecting SUPPORTED SYSTEM(S)
- 1. With a single SUPPORT SYSTEM(S) INOPERABLE, the affected SUPPORTED SYSTEM(S) Conditions and Required Actions are not required to be entered unless directed by
the SUPPORT SYSTEM(S) Required Actions.
- 2. The method to accomplish this will be in the form of a calculated Maximum Out Of Service Time (MOST). The MOST will ensure that a time limit is placed on the INOPERABLE SUPPORTED SYSTEM(S) such that when an additional SUPPORT SYSTEM(S) becomes INOPERABLE no extension of time is added to the original MOST. MOST is only used when implementing the SFDP.
- 3. The MOST is calculated in the following manner:
Support LCO Required Action
Completion Time + Supported LCO Required Action = MOST Completion Time Support Train A, LCO AAA (72hrs) +
Supported Train A, LCO BBB (72 hrs)=144 hrs
+ Supported Train A, LCO UUU (72 hrs)=144 hrs
+ Supported Train A, LCO ZZZ(72 hrs)=240 hrs
+ Supported Train A, LCO RRR (168 hrs) = 240 hrs
TRM Appendix C SFDP ATTACHMENT 2 (Continued)
SUPPORTED SYSTEM (S) COMPLETION TIME EXTENSIONS Quad Cities 1 & 2 C-20 Revision 0 EXAMPLE 1 Single SUPPORT SYSTEM(S) inoperable affecting SUPPORTED SYSTEM(S)
While in Mode 1, the A and B RHRSW SUBSYSTEM Pumps are declared inoperable at 0800 on 8/13/01. TS LCO 3.7.1 Conditions and Required Actions are entered. A LOSF is performed and all B train components are verified to be operable. Therefore, the TS LCO 3.0.6 and the SFDP can be implemented. All SUPPORTED SYSTEM(S) have been identified and the calculated MOST are as follows:
SUPPORT / SUPPORTED SYSTEM(S)
LCO CONDITION COMPLETION TIME MOST RHRSW Pump (A & B) Support 3.7.1 A.1 30 days RHRSW SUBSYSTEM Support 3.7.1 C.1 7 days RHR Suppression Pool Cooling Supported 3.6.2.4 A.1 7 days 14 days RHR Suppression Pool Spray Supported 3.6.2.4 A.1 7 days 14 days 3.7.1 Condition A applies to both inoperable pumps. One RHRSW pump must be operable at 0800 on 8/20/01 (7 days) at which time the RH R Suppression Pool Cooling and Spray are operable. The RHR Suppression Pool Cooling and Spray must be operable at 0800 on 8/27/01 (MOST). The second RHRSW pump must be operable at 0800 on 9/12/01 (30 days).
TRM Appendix C SFDP ATTACHMENT 2 (Continued)
SUPPORTED SYSTEM (S) COMPLETION TIME EXTENSIONS Quad Cities 1 & 2 C-21 Revision 0 EXAMPLE 2 With the A and B RHRSW pumps still inoperable, the A and B RHR pumps are determined to be inoperable at 0800 on 8/19/01. TS LCO 3.6.2.3, 3.6.2.4 Conditions and Required Actions are evaluated. It has been determined that both Condition 3.6.2.3.A and 3.6.2.4.A are now applicable.
SUPPORT / SUPPORTED SYSTEM(S)
LCO CONDITION COMPLETION TIME MOST RHRSW Pump (A & B) Support 3.7.1 A.1 30 days RHRSW SUBSYSTEM Support 3.7.1 C.1 7 days ECCS - Operating (LPCI A & B) Support 3.5.1.A.1 30 days ECCS - Operating Support 3.5.1.B.1 7 days RHR Suppression Pool Cooling Support 3.6.2.3 A.1 7 days RHR Suppression Pool Cooling Supported 3.6.2.3 A.1 7 days 14 days RHR Suppression Pool Spray Support 3.6.2.4 A.1 7 days RHR Suppression Pool Spray Supported 3.6.2.4 A.1 7 days 14 days One RHRSW pump must be operable at 0800 on 8/20/01 (7 days). The A and B RHR pumps must be operable at 0800 on 8/26/01 (7 days). The RHR Suppression Pool Cooling and Spray must still be operable at 0800 on 8/27/01 (MOST). The second RHRSW pump must still be operable at 0800 on 9/12/01 (30 days).
TRM Appendix C SFDP ATTACHMENT 2 (Continued)
SUPPORTED SYSTEM (S) COMPLETION TIME EXTENSIONS Quad Cities 1 & 2 C-22 Revision 0 EXAMPLE 3 The A RHRSW pump is declared operable at 1000 on 8/19/01 while the A and B RHR pumps remain inoperable. TS LCO 3.7.1 Conditions and Required Actions are evaluated. It has been determined that Condition 3.7.1.C for the RHRSW system is no longer applicable.
SUPPORT / SUPPORTED SYSTEM(S)
LCO CONDITION COMPLETION TIME MOST RHRSW Pump A Support 3.7.1 A.1 30 days ECCS - Operating (LPCI A & B) Support 3.5.1.A.1 30 days ECCS - Operating Support 3.5.1.B.1 7 days RHR Suppression Pool Cooling Support 3.6.2.3 A.1 7 days RHR Suppression Pool Spray Support 3.6.2.4 A.1 7 days RHR Suppression Pool Cooling Supported 3.6.2.3 A.1 7 days 14 days RHR Suppression Pool Spray Supported 3.6.2.4 A.1 7 days 14 days The RHR A and B pumps must be operable at 0800 on 8/26/01 (7 days) which supports the restoration of both RHR Suppr ession Pool Cooling / Spray and ECCS LCOs. The RHR Suppression Pool Cooling and Spray mu st be operable at 0800 on 8/27/01 (Original MOST). The second RHRSW pump must be ope rable at 0800 on 9/12/01 (30 days).
TRM Appendix C SFDP ATTACHMENT 2 (Continued)
SUPPORTED SYSTEM (S) COMPLETION TIME EXTENSIONS Quad Cities 1 & 2 C-23 Revision 0 EXAMPLE 4 With the A and B RHR and B RHRSW pumps still inoperable, the A RHRSW pump is again determined to be inoperable at 0800 on 8/25/01. TS LCO 3.7.1.C Conditions and Required Actions are entered.
SUPPORT / SUPPORTED SYSTEM(S)
LCO CONDITION COMPLETION TIME MOST RHRSW Pump (A & B) Support 3.7.1 A.1 30 days RHRSW SUBSYSTEM Support 3.7.1 C.1 7 days ECCS - Operating (LPCI A & B) Support 3.5.1.A.1 30 days ECCS - Operating Support 3.5.1.B.1 7 days RHR Suppression Pool Cooling Support 3.6.2.3 A.1 7 days RHR Suppression Pool Spray Support 3.6.2.4 A.1 7 days RHR Suppression Pool Cooling Supported 3.6.2.3 A.1 7 days 14 days RHR Suppression Pool Spray Supported 3.6.2.4 A.1 7 days 14 days The A and B RHR pumps must be operable at 0800 on 8/26/01. The RHR Suppression Pool Cooling and Sprays must be operable at 0800 on 8/27/01 (Original MOST).
Therefore, at least one of the RHRSW pumps must be operable 0800 on 8/27/01 in order for the RHR Suppression Pool Cooling and Spray to be operable.
If the B RHRSW pump is made operable, then the A RHRSW pump must be operable at 0800 on 9/13/01 (30 days + 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> exte nsion allowed by TS 1.3)
TRM Appendix C SFDP ATTACHMENT 2 (Continued)
SUPPORTED SYSTEM (S) COMPLETION TIME EXTENSIONS Quad Cities 1 & 2 C-24 Revision 0 EXAMPLE 5 A Division 1 Core Spray Pump Discharge Flow - Low (BYPASS) instrument has become inoperable. TS LCO 3.3.5.1 Conditions and Required Actions are entered. A LOSF is performed and all Division 2 components are verified to be operable. Therefore, the TS LCO 3.0.6 and the SFDP can be implemented. All SUPPORTED SYSTEM(S) have been identified and the calculated MO ST are as follows:
SUPPORT / SUPPORTED SYSTEM(S)
LCO CONDITION COMPLETION TIME MOST Core Spray Pump Discharge Flow Support 3.3.5.1 E.2 7 Days ECCS SYSTEM (CS) Supported 3.5.1 B.1 7 Days 14 Days In this example, the channel must be restored to operable status within 7 Days per Required Action 3.3.5.1.E.2, or the Supported CS pumps mu st be declared inoperable per 3.3.5.1.H..1.
TRM Appendix C SFDP ATTACHMENT 2 (Continued)
SUPPORTED SYSTEM (S) COMPLETION TIME EXTENSIONS Quad Cities 1 & 2 C-25 Revision 0 METHOD 2 Multiple SUPPORT SYSTEM(S) become INOPERABLE affecting the same SUPPORTED SYSTEM(S)
There may be some cases where two SUPPORT SYSTEMS for a common SUPPORTED SYSTEM become INOPERABLE simultaneously. In this case, the following method should be used to calculate the MOST.
- a. The first SUPPORT / SUPPORTED MOST plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or
- b. The subsequent SUPPORT / SUPPORTED MOST as measured from discovery of the first SUPPORT inoperability.
EXAMPLE 1- Multiple SUPPORT SYSTEM(S)
Two SUPPORT SYSTEM(S) become INOPERABLE at different times.
- 1. SYSTEMS B and C SU PPORT SYSTEM A.
SYSTEM B (SUPPORT SYSTEM) becomes INOPERABLE at T = 0 days.
- SYSTEM A (SUPPORTED SYSTEM) Completion Time - 3 days
- SYSTEM B (SUPPORT SYSTEM) Completion Time - 3 days
- SYSTEM C (SUPPORT SYSTEM) Completion Time - 7 days
- 2. SYSTEM B (SUPPORT SYSTEM) with a Completion Time of 3 days, renders SYSTEM A (SUPPORTED SYSTEM) INOPER ABLE. Method 1 is applied, which allows an overall MOST of 6 days for the SYSTEM A (SUPPORTED SYSTEM).
- 3. At T = 1 day, SYSTEM C (SUPPORT SYSTEM) becomes INOPERABLE and has a Completion Time of 7 days. SYSTEM C (SUPPORT SYSTEM) also supports SYSTEM A (SUPPORTED SYSTEM). SYSTEM B (SUPPORT SYSTEM) continues to remain INOPERABLE through its Completion Time T = 3 days.
- 4. Once SYSTEM C (SUPPORT SYSTEM) becomes INOPERABLE concurrent with SYSTEM B, Method 2 is applied at T=1, the Most is as follows:
Method 2a: Original MOST ( SY STEM A +B) + 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> = 7days, OR Method 2b: New MOST ( SYSTEM A + C ) = 10 days measured from T = 0.
TRM Appendix C SFDP Quad Cities 1 & 2 C-26 Revision 0 ATTACHMENT 3 SFDP TRACKING WORKSHEET INSTRUCTIONS The Safety Function Determination (SFD) Worksheet is used to document the supported systems of an I NOPERABLE SUPPORT SYSTEM, tr ack their Maximum Out Of Service Time (MOST), and document whether or not a lo ss of safety function exists. It is also the mechanism for documenting the reevaluation of safety function determinations that are necessary when subsequent LCO's are entered.
- 1. Enter the noun name of the INOPERABLE SUPPORT SYSTEM / component.
- 2. SUPPORT SYSTEM Tech Sp ec Condition / Required Action.
- 3. Date and time of entry into LCO Conditions and Required Actions for the SUPPORT SYSTEM.
- 4. Completion time allowed for the Required Ac tion of the SUPPORT SYSTEM Tech Spec.
- 5. Enter the noun name of each Tech Spec system supported by the INOPERABLE SUPPORT SYSTEM.
- 6. For each supported system, list the Tech Spec Condition / Required Action.
- 7. Record the allowed completion time for the supported system Required Action.
- 8. Perform a cross train check (ATTACHMENT 1/ Method 1 and TABLE 1) to verify operability of the INOPERABLE supported system's redundant equipment, as well as the support features for the redundant equipment. Bl ock 8 is filled in with yes or no.
TRM Appendix C SFDP ATTACHMENT 3 (Continued)
SFDP TRACKING WORKSHEET Quad Cities 1 & 2 C-27 Revision 0
- 9. Based on the results of the cross train check performed in step 8 of the worksheet, determine whether or not the safety func tion of the supported system has been lost. If the cross train check, ATTACHME NT 1/ Method 1 has failed or can not be performed, Methods 2 or 3 may be used to assess the status of the safety function in question. If the safety function has been lost, then enter the appro priate Conditions and Required Actions for that system or component using the following guidance: 1. SINGLE SU PPORT SYSTEM INOPERABILITY- When a LOSF is solely due to a single T.S. SUPPORT SYSTEM ( e.g., loss of a pump suction source due to low tank level ) the appropriate LCO is the LCO for the SUPPORT SYSTEM. The Actions for the SUPPORT SYSTEM LCO adequately address the inoperabilities of that system without reliance upon the Actions of the SUPPORTED SYSTEM. 2.
MULTIPLE SUPPORT SYSTEM INOPERABILITY- When a LOSF is due to multiple T.S. SUPPORT SYSTEM inoperabilities, the appropriate LCO is the LCO for the SUPPORTED SYSTEMS.
- 10. If the safety function has not been lost or LOSF is solely due to a single T.S. support system, calculate the Maximum Out of Service Time for the supported system. If ATTACHMENT 2 Method 1 is used, this will be the sum of block 4 and block 7. If Method 2 is used, see ATTACHMENT 2.
- 11. Expiration time: Time determined in either Method 1 or 2 ATTACHMENT 2 measured from the time in step 3 (Date/Time Entered) in HR: MIN on the MM/DD/YR.
- 12. The comment block can be used to record any notes or other references.
- 13. Preparer sign and date.
- 14. Sign and date for Verification of the SFD, indicating that you c oncur with the listed results.
- 15. As subsequent inoperabilities occur, all existing SFD's must be reviewed to determ ine their validity. Record the new LCO C ondition and Required Actions and initial and da te indicating either yes, the SFD is still valid, or no the SFD is no longer valid. If the SFD is no longer valid based on the new LCO Conditions and Required Actions, a new SFD must be performed. Attach the new SFD to the now invalid SFD.
- 16. The SFD may be closed out when the INOPERABLE SUPPORT SYSTEM and SUPPORT ED SYSTEM(S) listed on the SFDP Tracking Sheet are returned to OPERABLE STATUS. Enter the Time and Date when the SUPPORT SYSTEM and SUPPORTED SYSTEM(S) are returned to OPERABLE STATUS and sign the Worksheet.
TRM Appendix C SFDP ATTACHMENT 3 (Continued)
SFDP TRACKING WORKSHEET Quad Cities 1 & 2 C-28 Revision 0 SUPPORT SYSTEM INOPERABLE
- 4. Completion Time SUPPORTED SYSTEMS / COMPONENTS 5. Supported System Name 6. T.S. Condition / Required Action 7. Completion Time 8. Redundant Inoperability? 9. Loss of Safety Function? 10. M.O.S.T. 11. Expiration Time 12. Comments
TRM Appendix C SFDP ATTACHMENT 3 (Continued)
SFDP TRACKING WORKSHEET Quad Cities 1 & 2 C-29 Revision 0 SFDP REVIEW FOR SUBSEQUENT INOPERABILITIES NEW LCO CONDITION #
SFDPs VALID (Y / N) VERIFIED BY (INITIAL / DATE)
TRM Appendix C SFDP Quad Cities 1 & 2 C-30 Revision 0 TABLE 1 CROSS TRAIN CHECK GUIDANCE Guidelines for Performing Cross Train Checks The following matrix is meant to list possible SUPPORT to SUPPORTED LCO relationships for the purpose of implementing the cross train checks as required by LCO 3.0.6. and 5.5.11.
This matrix does NOT:
- Cover all possible combinations or permutations of SUPPORT / SUPPORTED LCO relationships.
- Cover SUPPORT / SUPPORTED relationships for items outside of Tech Spec (i.e., room coolers or snubbers).
- Cover SUPPORT / SUPPORTED relationships for LCOs that are NOT applicable in a given mode
- Cover Technical Requirement Manual LCOs or features.
- Include Support Features and Supported Systems if the Required Actions for the INOPERABLE Support Feature direct the entry into the TS ACTIONS for the Supported System. The purpose behind this matrix is to provide guidance when assessing a LOSF on based on SUPPORTED system LCOs, due to inoperability of a SUPPORT SYSTEM LCO.
The following minimum items should be considered when evaluating the redundant train:
- Panel Walkdown
- DEL Review
- Schedule Review
- Current Outage Reports
- Physical walkdown as needed by the US
- OOS Review
- Operability Evaluations Each situation should be assessed on its own merit, to determine LCO impact.
TRM Appendix C SFDP Quad Cities 1 & 2 C-31 Revision 0 TABLE 1 (Continued)
CROSS TRAIN CHECK GUIDANCE Support Feature TS
Number
Support Feature Supported
System TS
Number
Supported System 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation 3.5.1
3.5.2
3.8.1
3.8.2 ECCS - Operating
ECCS - Shutdown
AC Sources - Operating
AC Sources - Shutdown 3.3.5.2 Reactor Core Isolation Cooling (RCIC) System Instrumentation3.5.3 RCIC System 3.3.6.1 Primary Containment Isolation Instrumentation 3.1.7
3.4.7
3.4.8
3.6.1.3
3.9.8
3.9.9 Standby
Liquid Control (SLC) System
Shutdown Cooling System - Hot
Shutdown
Shutdown Cooling System - Cold
Shutdown
Primary Containment Isolation Valves (PCIVs) Residual Heat Removal (RHR)
Residual Heat Removal (RHR) - High
Water Level
Residual Heat Removal (RHR) - Low
Water Level 3.3.6.2 Secondary Containment Isolation Instrumentation 3.6.4.2
3.6.4.3 Secondary Containment Isolation Valves (SCIVs)
Standby Gas Treatment (SGT) System 3.3.6.3 Relief Valve Instrumentation 3.4.3
3.6.1.6 Safety and Relief Valves
Low Set Relief Valves
TRM Appendix C SFDP Quad Cities 1 & 2 C-32 Revision 0 Support Feature TS
Number
Support Feature Supported
System TS
Number
Supported System 3.3.7.1 Control Room Emergency Ventilation (CREV) System Instrumentation 3.7.4 Control Room Emergency Ventilation (CREV) System 3.3.8.1 Loss of Power (LOP) System Instrumentation 3.3.5.1
3.8.1
3.8.2 Emergency
Core Cooling System (ECCS) Instrumentation
AC Sources - Operating
AC Sources - Shutdown 3.6.1.7 Reactor Building-to-Suppression Chamber Vacuum
Breakers 3.6.1.1 Primary Containment 3.6.1.8 Suppression Chamber-to-Drywell Vacuum Breakers Secondary Containment Isolation Valves (SCIVs) 3.6.1.1 Primary Containment 3.6.4.2 Secondary Containment Isolation Valves (SCIVs) 3.6.4.1 Secondary Containment 3.6.4.3 Standby Gas Treatment (SGT) System 3.6.4.1 Secondary Containment
TRM Appendix C SFDP Quad Cities 1 & 2 C-33 Revision 0 TABLE 1 (Continued)
CROSS TRAIN CHECK GUIDANCE Support Feature TS
Number
Support Feature Supported
System TS
Number
Supported System 3.7.1 Residual Heat Removal Service Water (RHRSW) System 3.4.7
3.4.8
3.6.2.3
3.6.2.4
3.7.5
3.9.8
3.9.9 Residual
Heat Removal (RHR)
Shutdown Cooling System - Hot
Shutdown
Shutdown Cooling System - Cold
Shutdown
Suppression Pool Cooling
Suppression Pool Spray
Control Room Emergency Ventilation Air Conditioning (AC) System
Residual Heat Removal (RHR) - High
Water Level
Residual Heat Removal (RHR) - Low
Water Level 3.7.2 Diesel Generator Cooling Water (DGCW) System 3.5.1
3.5.2
3.8.1
3.8.2 ECCS - Operating
ECCS - Shutdown
AC Sources - Operating
AC Sources - Shutdown 3.7.3 Ultimate Heat Sink (UHS) 3.7.1
3.7.2 Residual
Heat Removal Service Water (RHRSW) System
Diesel Generator Cooling Water (DGCW) System 3.8.1 AC Sources - Operating 3.8.7 Distribution System - Shutdown (AC Portion Only) 3.8.2 AC Sources - Shutdown 3.8.8 Distribution System - Shutdown (AC Portion Only) 3.8.4 DC Sources - Operating 3.8.7 Distribution System - Shutdown (DC Portion Only) 3.8.5 DC Sources - Shutdown 3.8.8 Distribution System - Shutdown (DC Portion Only)
TRM Appendix C SFDP TABLE 1 (Continued)
CROSS TRAIN CHECK GUIDANCE Quad Cities 1 & 2 C-34 Revision 0 Support Feature TS
Number Support Feature Supported System TS
Number Supported System 3.8.7 (AC Only)
Distribution System -
Operating (AC portion Only) 3.1.7
3.3.3.1
3.3.5.1
3.3.5.2
3.3.6.1
3.3.6.2
3.3.7.1
3.4.4
3.4.5
3.4.7
3.5.1
3.5.3 Standby
Liquid Control (SLC)
System
Post Accident Monitoring (PAM)
Instrumentation
Emergency Core Cooling System (ECCS) Instrumentation
Isolation Condenser (IC) System Instrumentation (17 & 20 valves)
Primary Containment Isolation Instrumentation
Secondary Containment Isolation Instrumentation
Control Room Emergency Ventilation (CREV) System Instrumentation
RCS Leakage Detection Instrumentation
Shutdown Cooling System - Hot
Shutdown
Emergency Core Cooling System (ECCS) - Operating
RCIC System
TRM Appendix C SFDP TABLE 1 (Continued)
CROSS TRAIN CHECK GUIDANCE Quad Cities 1 & 2 C-35 Revision 0 Support Feature TS
Number Support Feature Supported System TS
Number Supported System 3.8.7 (continued)
(AC Only)
Distribution System -
Operating (AC portion Only) 3.6.1.3
3.6.2.3
3.6.2.4
3.6.4.2
3.6.4.3
3.7.1
3.7.2
3.7.4
3.7.5
3.7.9
3.8.1
3.8.3
3.8.4 Primary
Containment Isolation
Valves (PCIVs)
Suppression Pool Cooling
Suppression Pool Spray
Secondary Containment Isolation Valves (SCIVs)
Standby Gas Treatment (SGT)
System
Residual Heat Removal Service Water (RHRSW) System
Diesel Generator Cooling Water (DGCW) System
Control Room Emergency Ventilation (CREV) System
Control Room Emergency Ventilation Air Conditioning (AC) System
Safe Shutdown Makeup Pump (SSMP) System
AC Sources - Operating
Diesel Fuel Oil and Starting Air
DC Sources - Operating
TRM Appendix C SFDP TABLE 1 (Continued)
CROSS TRAIN CHECK GUIDANCE Quad Cities 1 & 2 C-36 Revision 0 Support Feature TS
Number Support Feature Supported System TS
Number Supported System 3.8.7 (DC Only) Distribution Systems -
Operating (DC Only) 3.3.3.1
3.3.4.1
3.3.5.1
3.3.5.2
3.3.6.1
3.3.8.1
3.3.8.2
3.4.3
3.4.7
3.5.1 Post Accident Monitoring (Pam) Instrumentation
Anticipated Transient Without SCRAM Recirculation Pump
Trip (ATWS-RPT)
Instrumentation
Emergency Core Cooling System (ECCS) Instrumentation
Reactor Core Isolation Cooling (RCIC) System Instrumentation
Primary Containment Isolation Instrumentation
Loss of Power (LOP) System Instrumentation
Reactor Protection System (RPS) Electric Power Monitoring
Safety and Relief Valves
Shutdown Cooling System -
Hot Shutdown
Emergency Core Cooling System (ECCS) - Operating
TRM Appendix C SFDP TABLE 1 (Continued)
CROSS TRAIN CHECK GUIDANCE Quad Cities 1 & 2 C-37 Revision 0 Support Feature TS
Number Support Feature Supported System TS
Number Supported System 3.8.7 (continued)
(DC Only) Distribution Systems -
Operating (DC Portion Only) 3.5.3
3.6.1.3
3.6.2.3
3.6.2.4
3.7.1
3.7.2
3.8.1 RCIC System
Primary Containment Isolation
Valves (PCIVs)
Suppression Pool Cooling
Suppression Pool Spray
Residual Heat Removal Service
Diesel Generator Cooling Water (DGCW) System
AC Sources - Operating
TRM Appendix C SFDP TABLE 1 (Continued)
CROSS TRAIN CHECK GUIDANCE Quad Cities 1 & 2 C-38 Revision 0 Support Feature TS
Number Support Feature Supported System TS
Number Supported System 3.8.8 (AC Only) Distribution Systems -
Shutdown (AC Portion Only) 3.3.5.1
3.3.6.1
3.3.6.2
3.3.7.1
3.4.8
3.5.2
3.6.1.3 3.6.4.2 Emergency Core Cooling System (ECCS) Instrumentation
Primary Containment Isolation Instrumentation
Secondary Containment Isolation Instrumentation
Control Room Air Filtration (CREV) System Instrumentation
Shutdown Cooling System Cold
Shutdown
Emergency Core Cooling System (ECCS) - Shutdown
Primary Containment Isolation Valves (PCIVs)
Secondary Containment Isolation Valves (SCIVs)
TRM Appendix C SFDP TABLE 1 (Continued)
CROSS TRAIN CHECK GUIDANCE Quad Cities 1 & 2 C-39 Revision 0 Support Feature TS
Number Support Feature Supported System TS
Number Supported System 3.8.8 (continued)
(AC Only) Distribution Systems -
Shutdown (AC Portion Only) 3.6.4.3
3.7.1
3.7.2
3.7.4
3.7.5
3.8.2
3.8.3
3.8.5
3.9.8
3.9.9 Standby
Gas Treatment (SGT) System
Residual Heat Removal Service Water (RHRSW) System
Diesel Generator Cooling Water (DGCW) System
Control Room Emergency Ventilation (CREV) System
Control Room Emergency Ventilation Air Conditioning (AC) System
AC Sources - Shutdown
Diesel Fuel Oil and Starting Air
DC Sources - Shutdown
Residual Heat Removal (RHR) - High Water Level
Residual Heat Removal (RHR) - Low
Water Level
TRM Appendix C SFDP TABLE 1 (Continued)
CROSS TRAIN CHECK GUIDANCE Quad Cities 1 & 2 C-40 Revision 0 Support Feature TS
Number Support Feature Supported System TS
Number Supported System 3.8.8 (DC Only) Distribution Systems -
Shutdown (DC Portion Only) 3.3.5.1
3.3.6.1
3.3.8.1
3.3.8.2
3.4.8
3.5.2
3.6.1.3 3.8.2
3.9.8
3.9.9 Emergency
Core Cooling System (ECCS) Instrumentation
Primary Containment Isolation Instrumentation
Loss of Power (LOP) System Instrumentation
Reactor Protective System (RPS) Electric Power
Monitoring
Shutdown Cooling System -
Cold Shutdown
ECCS - Shutdown
Primary Containment Isolation
Valves (PCIVs)
AC Sources - Shutdown
High Water Level
Low Water Level
TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 1 of 15 Revision QC-TRM-05-001 Technical Requirements Manual TECHNICAL SPECIFICATIONS BASES CONTROL PROGRAM TABLE OF CONTENTS SECTION TITLE
1.1 PURPOSE
1.2 REFERENCES
1.3 DEFINITIONS
AND/OR ACRONYMS
1.4 PROGRAM
DESCRIPTION
1.5 PROGRAM
IMPLEMENTATION
1.6 ACCEPTANCE
CRITERIA 1.7 LCOARS/COMPENSATORY MEASURES
1.8 REPORTING
REQUIREMENTS
1.9 CHANGE
CONTROL TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 2 of 15 Revision QC-TRM-05-001 Technical Requirements Manual
1.1 PURPOSE
The purpose of this Program is to provide guidance for identifying, processing, and implementing changes to the Technical Specifications (TS) Bases. This Program implements and satisfies the requirements of TS 5.5.10, "Technical Specifications (TS)
Bases Control Program."
This Program is applicable to the preparation, review, implementation, and distribution of changes to the TS Bases. This Program also provides guidance for preparing TS Bases Change Packages for distribution.
1.2 REFERENCES
- 1. TS 5.5.10, "Technical Specifications (TS) Bases Control Program"
- 2. 10 CFR 50.4, "Written Communications" 3. 10 CFR 50.59, "Changes, Tests and Experiments"
- 4. 10 CFR 50.71, "Maintenance of Records, Making of Reports" 5. 10 CFR 50.90, "Application for Amendment of License or Construction Permit"
1.3 DEFINITIONS
AND/OR ACRONYMS
- 1. 10 CFR 50.59 REVIEW - A written regulatory evaluation which provides the basis for the determination that a change does, or does not, require NRC approval pursuant to 10 CFR 50.59.
The scope of the evaluation should be commensurate with the potential safety significance of the change, but must address the relevant safety concerns included in the Safety Analysis Report and other owner controlled documents. The depth of the evaluation must be sufficient to determine whether or not NRC approval is required prior to implementation. Depending upon the significance of the
change, the evaluation may be brief; however, a simple statement of conclusion is not sufficient.
TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 3 of 15 Revision QC-TRM-05-001 Technical Requirements Manual 2. EDITORIAL CHANGE - Editorial changes include correction of punctuation, insignificant word or title changes, style or format changes, typographical errors, or correction of
reference errors that do not change the intent, outcome, results, functions, processes, responsibilities, or performance requirements of the item being changed. Changes in numerical values shall not be considered as editorial changes. Editorial changes do not constitute a change to the TRM and therefore do not require further 10 CFR 50.59 Reviews. If the full scope of this proposed change is encompassed by one or more of the below, then the change is considered editorial.
- Rewording or format changes that do not result in changing actions to be accomplished. - Deletion of cycle-specific information that is no longer applicable. - Addition of clarifying information, such as: - Spelling, grammar, or punctuation changes - Changes to references - Name or title references
1.4 PROGRAM
DESCRIPTION
- 1. A Licensee may make changes to the TS Bases without prior NRC approval provided the changes do not require either of the following:
- a. A change in the TS as currently incorporated in the license; or
- b. A change to the Updated Final Safety Analysis Report (UFSAR) or TS Bases that requires NRC approval pursuant to 10 CFR 50.59.
- 2. Changes that meet the above criteria (i.e., 1.4.1.a or 1.4.1.b) shall be submitted to the NRC pursuant to
10 CFR 50.90 and reviewed and approved by the NRC prior to implementation.
- 3. The TS Bases shall be maintained consistent with the UFSAR.
TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 4 of 15 Revision QC-TRM-05-001 Technical Requirements Manual 4. If a change to the TS Bases is not consistent with the UFSAR, then the cognizant Engineer shall prepare and submit a UFSAR Change Package when the TS Bases Change Request is
submitted to Regulatory Assurance (RA) for processing.
- 5. Changes to the TS Bases that do not require prior NRC approval shall be provided to the NRC on a frequency
consistent with 10 CFR 50.71(e), as modified by approved
exemptions.
- 6. Any change to a Station's TS Bases shall be transmitted, via Attachment D, "Technical Specifications Bases Change
Applicability Review Form," to the Regulatory Assurance Managers (RAMs) at each of the other Stations. The RAM will review the TS Bases change for applicability at their
respective Station and document their review on Attachment D.
- 7. TS Bases changes associated with a TS Amendment shall be implemented consistent with the implementation requirements
of the TS Amendment.
- 8. Cantera Licensing (CL) is responsible for the control and distribution of the TS Bases. In order to prevent
distribution errors (i.e., omissions or duplications), CL shall maintain the master TS Bases distribution list.
1.5 PROGRAM
IMPLEMENTATION
- 1. TS Bases Change Requestor identifies the need for a revision to the TS Bases and notifies the RA Licensing Engineer (i.e., hereafter referred to as RA LE). A TS Bases change can be initiated through any Stations' RA. TS Bases Change
Requestor notifies their counterparts on the need for a change.
- 2. RA LE notifies their counterparts of identified need for revision to the TS Bases.
- 3. RA LE obtains concurrence from CL on the need for a change.
TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 5 of 15 Revision QC-TRM-05-001 Technical Requirements Manual 4. CL Engineer (i.e., hereafter referred to as CLE) assigns a TS Bases Change Request Number (CR #) and records on Attachment B, "Technical Specifications Bases Change Request Log." The
CR # should be a sequential number beginning with the last two digits of the year (e.g., 00-00#).
- 5. RA LE drafts TS Bases changes considering format, rules of usage, and technical adequacy, and notifies RAMs at each of the other Stations by transmitting Attachment D, "Technical Specifications Bases Change Applicability Review Form."
- 6. CLE reviews the agreed upon TS Bases wording changes for consistency with format, rules of usage, and technical
adequacy and provides final concurrence.
- 7. After concurrence of the TS Bases wording changes is obtained, CLE makes an electronic version available in a working directory for use in the preparation of the 10 CFR 50.59 REVIEW and Station Qualified Review (SQR) process. The CLE shall ensure that the master electronic TS Bases files are revised per step 15 below upon receiving SQR approval. The Revision number in the footer should be a sequential number (i.e., 1, 2, etc.).
- NOTE If the TS Bases changes are applicable to more than one Station, the following steps should be performed concurrently for each Station.
- 8. TS Bases Change Requestor provides a 10 CFR 50.59 REVIEW for the TS Bases changes in accordance with appropriate plant procedures. An exception to this requirement applies when the changes are being requested in order to reflect an approved NRC Safety Evaluation (SE) associated with a site specific Operating License or TS change. The NRC SE is sufficient to support the changes provided it has been determined that the changes are consistent with and entirely bounded by the NRC SE. A 10 CFR 50.59 REVIEW shall be performed for TS Bases changes that reflect generic industry approval by an NRC SE to determine site specific applicability. A 10 CFR 50.59 REVIEW is not required for an EDITORIAL CHANGE.
TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 6 of 15 Revision QC-TRM-05-001 Technical Requirements Manual 9. TS Bases Change Requestor completes Attachment A, "Technical Specifications Bases Change Request Form," as follows:
- a. Identifies the affected sections, and includes a copy of the proposed TS Bases changes;
- b. Briefly summarizes the changes including the LCO, Action, or Surveillance Requirement to which the changes apply;
- c. Briefly summarizes the reason for the changes and attaches all supporting documentation;
- d. Identifies any schedule requirements and proposed implementation date that apply (i.e., describe any time limitations that might apply which would require expedited processing). If the changes are outage related, then checks "yes" and lists the applicable outage identifier;
- e. Identifies any known implementation requirements such as procedure changes, UFSAR changes, Passport changes, Reportability Manual revisions, pre-
implementation training requirements, etc.;
- f. If a 10 CFR 50.59 REVIEW was prepared to support the TS Bases changes, the Requestor then checks the appropriate box, lists the associated 10 CFR 50.59 REVIEW Number, and attaches the original;
- g. If the changes to the TS Bases are the result of an approved NRC SE associated with a site specific Operating License or TS change and the scope of the changes determined to be consistent with and entirely bounded by the NRC SE, then the Requestor checks the appropriate box and attaches a copy;
- h. If the changes to the TS Bases are EDITORIAL CHANGES, the the Requestor checks the appropriate box and no 10
CFR 50.59 REVIEW is required;
- i. Signs and dates as Requestor and identifies the originating department;
TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 7 of 15 Revision QC-TRM-05-001 Technical Requirements Manual j. Obtains approval to proceed from Department Supervisor (or designee); and
- k. Returns Attachment A to the RA LE.
- 10. RA LE reviews the TS Bases Change Request Form, including supporting documentation, and documents the review by signing Attachment A. The review verifies that the
following information or documentation is included:
- a. Completed 10 CFR 50.59 REVIEW. If the changes are related to an approved NRC SE associated with a site specific Operating License or TS change and determined to be entirely bounded by the NRC SE, then
only a copy of the SE is required to be attached and
no 10 CFR 50.59 REVIEW is required. A 10 CFR 50.59 REVIEW is not required for an EDITORIAL CHANGE;
- b. Identification of known documents requiring revisions; and c. Completed UFSAR Change Request with supporting documentation, in accordance with appropriate plant procedures, if applicable.
- 11. If the TS Bases change is not an EDITORIAL CHANGE, the RA LE/TS Bases Change Requestor obtains SQR approval of the TS Bases changes by performing the following:
- a. RA LE prepares the TS Bases Change SQR package. The SQR package shall include Attachment A (including completed 10 CFR 50.59 REVIEW or NRC SE) and the revised TS Bases pages. Attachment A is provided for the purpose of reviewing and finalizing the
implementation requirements and ensuring the necessary actions have been initiated. RA LE shall assign Action Tracking (AT) items, as necessary, to track implementation requirements;
- b. TS Bases Change Requestor submits the TS Bases Change SQR package to the SQR Committee members for a preliminary review. The SQR composition shall include RA and Operating Departments in all cases; and TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 8 of 15 Revision QC-TRM-05-001 Technical Requirements Manual c. TS Bases Change Requestor resolves preliminary review comments and finalizes the TS Bases Change SQR package.
- 12. The RAM shall determine the need for Plant Operations Review Committee (PORC) approval. The need for PORC approval shall
be documented on Attachment A.
- 14. RA LE notifies CLE of approval of the TS Bases changes by forwarding a copy of the approved SQR/PORC Change package to CLE. 15. After approval of the TS Bases changes by SQR/PORC, CLE ensures that the controlled master electronic files are
updated.
- 16. CL/RA completes Attachment C, "Technical Specifications Bases Change Instruction Form," as follows:
- a. CLE indicates the effective date of the TS Bases changes consistent with the SQR/PORC approval or TS amendment required implementation date. If the TS Bases change is a result of a TS Amendment, the update shall be implemented coincident with implementation
requirements of the TS Amendment. Otherwise, the update must be implemented by the date indicated on Attachment C;
- b. CLE lists each page to be removed and inserted, including the Affected Page List; and
- c. RA LE provides the updated master file directory for updating Electronic Document Management System (EDMS), if applicable.
- 17. CLE creates a TS Bases Change Package. The TS Bases Change Package shall consist of:
- a. TS Bases Change Instruction Form (Attachment C);
- b. Revised Affected Page List; and TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 9 of 15 Revision QC-TRM-05-001 Technical Requirements Manual c. Revised TS Bases pages.
One CLE shall assemble and approve the TS Bases Change Package for distribution and a second CLE shall perform a peer check to verify completeness of the TS Bases Change
Package. 18. After the RA LE notifies the CLE that SQR/PORC approval of the TS Bases changes has been obtained and that all AT items assigned to track implementation requirements have been completed, CLE forwards the TS Bases Change Package to the RA LE as notification of the need to update the onsite TS
Bases controlled copies and EDMS, if applicable. CLE also forwards the TS Bases Change Package to CL Records Management as notification of the need to update the offsite (CL) TS Bases controlled copies and to transmit updates to the offsite (non-CL) TS Bases controlled copies.
- 19. RA LE forwards the TS Bases Change Package to Station Records Management as notification of the need to update the onsite TS Bases controlled copies and EDMS, if applicable.
- 20. Upon completion of updating the onsite TS Bases controlled copies and EDMS (if applicable), Station Records Management Supervisor signs and dates Attachment C and returns Attachment C to the appropriate CLE.
- 21. Upon completion of updating the offsite (CL) TS Bases controlled copies and transmitting updates to the offsite (non-CL) TS Bases controlled copies, CL Records Management signs and dates Attachment C and returns Attachment C to the appropriate CLE.
- 22. CLE updates the TS Bases Change Request Log (Attachment B) with the following information:
- a. 10 CFR 50.59 REVIEW Number;
- b. SQR Number, if applicable;
- c. SQR Approval Date; and
- d. TS Bases change implementation date.
TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 10 of 15 Revision QC-TRM-05-001 Technical Requirements Manual 23. RA LE ensures that the documentation required to be maintained as a quality record is provided to Station Records Management for the purpose of record retention.
1.6 ACCEPTANCE
CRITERIA Not applicable.
1.7 LCOARS/COMPENSATORY MEASURES An Issue Report may need to be generated to provide proper tracking and resolution of noted problems associated with the
implementation of this Program.
The RAM will be responsible for ensuring that Program failures have been resolved.
1.8 REPORTING
REQUIREMENTS
- NOTE TS Bases changes requiring prior NRC approval shall be submitted in accordance with Reference 5.
TS Bases changes not requiring prior NRC approval, as described in Section 1.4 of this Program, shall be submitted to the NRC in accordance with 10 CFR 50.71(e).
1.9 CHANGE
CONTROL
Changes to this Program, other than EDITORIAL CHANGES, shall include a 10 CFR 50.59 REVIEW and a SQR. The SQR composition shall include RA Department in all cases. For a change to this Program, PORC approval from all Stations is required. The concurrence shall
be that the other Stations are implementing the same changes or that the changes have been reviewed and determined not to be applicable to the other Stations.
TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 11 of 15 Revision QC-TRM-05-001 Technical Requirements Manual ATTACHMENT A TECHNICAL SPECIFICATIONS BASES CHANGE REQUEST FORM
- 1. Change Request #: _____________ Affected Bases Section(s): ________________________
- 2. Description of changes: __________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
- 3. Reason for changes (attach all supporting documentation): _____________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
- 4. Schedule Requirements: Outage Related (check one) No Yes, Outage # ___________ Other (explain) ____________________________________________________________________
- 5. Implementation Requirements (attach additional pages, as necessary):
Identify the impact of the changes on the following: Affected N/A UFSAR ______________________________________________________________
TS _________________________________________________________________
Technical Requirements Manual ______________________________________
NRC Safety Evaluation ______________________________________________
Fire Protection Report _____________________________________________
NRC Commitments ____________________________________________________
Vendor Documentation _______________________________________________
Special Permits/Licenses ___________________________________________
Procedures _________________________________________________________
Environmental Qualification ________________________________________
Design Basis Documentation _________________________________________
Engineering Calculations ___________________________________________
Drawings/Prints ____________________________________________________
PRA Information ____________________________________________________
Programs ___________________________________________________________
Reportability Manual _______________________________________________
QA Topical Report __________________________________________________
Passport ___________________________________________________________
Pre-Implementation Training Required _______________________________
Maintenance Rule ___________________________________________________
Offsite Dose Calculation Manual ____________________________________
Other ______________________________________________________________
- 6. Check one:
10 CFR 50.59 REVIEW Attached, 10 CFR 50.59 REVIEW #:_________________________
NRC SE Attached, Changes consistent with and entirely bounded by NRC SE EDITORIAL CHANGE, No 10 CFR 50.59 REVIEW required
- 7. Requestor: ______________________/______________________/________________________ (Signature) (Date) (Department)
- 8. Requesting Supervisor Approval: _______________________/________________________ (Signature) (Date)
- 9. PORC Approval Required: Yes No
- 10. Licensing Engineer Review: _______________________/________________________
(Signature) (Date)
TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 12 of 15 Revision QC-TRM-005-001 Technical Requirements Manual ATTACHMENT B TECHNICAL SPECIFICATIONS BASES CHANGE REQUEST LOG CR # Brief Description of Changes Affected Section(s) 10 CFR 50.59 REVIEW # SQR # SQR Approval Date Date Implemented TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 13 of 15 Revision QC-TRM-05-001 Technical Requirements Manual ATTACHMENT C TECHNICAL SPECIFICATIONS BASES CHANGE INSTRUCTION FORM FOR ONSITE/OFFSITE DISTRIBUTION AND FOR UPDATING EDMS
Braidwood/Byron/Dresden/LaSalle/QC (circle one) TS Bases Revision # ______
NOTE: This change is effective as of _____________________________ and shall be implemented by __________ . (SQR/PORC or Amendment Implementation Date) (Date)
Approved for distribution: ___________________________________/_____________ (CLE Signature) (Date)
Verified: ___________________________________/_____________ (CLE Signature) (Date)
REMOVE Section REMOVE Page INSERT Section INSERT Page UPDATE EDMS Section UPDATE EDMS Page Affected
Page List All Affected Page List All N/A N/A
TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 14 of 15 Revision QC-TRM-05-001 Technical Requirements Manual ATTACHMENT C TECHNICAL SPECIFICATIONS BASES CHANGE INSTRUCTION FORM FOR ONSITE/OFFSITE DISTRIBUTION AND FOR UPDATING EDMS Braidwood/Byron/Dresden/LaSalle/QC (circle one) TS Bases Revision # ______
___________________________________________________________________________________________
Station Records Management:
Onsite Distribution Completed: ______________________________/___________________
(Station Records Mgmt. Supr.) (Date)
EDMS Update Completed: ______________________________/___________________ (Station Records Mgmt. Supr.) (Date)
- Return this sheet to: Cantera Licensing Braidwood/Byron/Dresden/LaSalle/QC (circle one) CL CANTERA
___________________________________________________________________________________________
CL Records Management:
Offsite (CL) Distribution Completed: ___________________________/____________________ (CL Records Mgmt.) (Date)
Offsite (non-CL) Distribution Transmitted:
___________________________/____________________ (CL Records Mgmt.) (Date)
- Return this sheet to Braidwood/Byron/Dresden/LaSalle/QC (circle one) CL
___________________________________________________________________________________________
Offsite (non-CL) Controlled Copy Holders:
Offsite (non-CL) Distribution Completed: ___________________________/____________________ (Signature) (Date)
- Return this sheet to: EXELON GENERATION COMPANY, LLC LICENSING AND REGULATORY AFFAIRS DEPARTMENT 4300 WINFIELD ROAD WARRENVILLE, IL 60555
TRM TS Bases Control Program Appendix D Quad Cities Units 1 & 2 15 of 15 Revision QC-TRM-05-001 Technical Requirements Manual ATTACHMENT D TECHNICAL SPECIFICATIONS BASES CHANGE APPLICABILITY REVIEW FORM Any change to a Station's Technical Specifications (TS) Bases shall be transmitted to the
Regulatory Assurance Managers (RAMs) at each of the other Stations. The RAM will review the TS Bases change for applicability at their respective Station. Review of applicability shall be documented on this Attachment and forwarded to the Regulatory Assurance Licensing
Engineer(s) at the Station(s) making the change.
Braidwood/Byron/Dresden/LaSalle/QC (circle one)
TS Bases Section(s)/Title(s): _____________________________________________________________
Description of the change: _________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Braidwood RAM Review: ________________________/_______________ (Signature) (Date)
Change Applicable: Yes No Byron RAM Review: ________________________/_______________ (Signature) (Date)
Change Applicable: Yes No Dresden RAM Review: ________________________/_______________
(Signature) (Date)
Change Applicable: Yes No LaSalle RAM Review: ________________________/_______________ (Signature) (Date)
Change Applicable: Yes No QC RAM Review: ________________________/_______________ (Signature) (Date)
Change Applicable: Yes No
- Return this sheet to: Regulatory Assurance Braidwood/Byron/Dresden/LaSalle/QC (circle one) Station
TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 1 of 15 Revision QC-TRM-05-001 Technical Requirements Manual TECHNICAL REQUIREMENTS MANUAL CONTROL PROGRAM TABLE OF CONTENTS
SECTION TITLE 1.1 PURPOSE
1.2 REFERENCES
1.3 DEFINITIONS
AND/OR ACRONYMS
1.4 PROGRAM
DESCRIPTION
1.5 PROGRAM
IMPLEMENTATION
1.6 ACCEPTANCE
CRITERIA 1.7 LCOARS/COMPENSATORY MEASURES
1.8 REPORTING
REQUIREMENTS
1.9 CHANGE
CONTROL
TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 2 of 15 Revision QC-TRM-05-001 Technical Requirements Manual
1.1 PURPOSE
The purpose of this Program is to provide guidance for
identifying, processing, and implementing changes to the Technical Requirements Manual (TRM). This Program implements and satisfies the requirements of TRM Section 1.6, "Technical Requirements Manual Revisions."
This Program is applicable to the preparation, review, implementation, and distribution of changes to the TRM. This Program also provides guidance for preparing TRM Change Packages for distribution.
1.2 REFERENCES
- 1. TRM Section 1.6, "Technical Requirements Manual Revisions" 2. 10 CFR 50.4, "Written Communications" 3. 10 CFR 50.59, "Changes, Tests and Experiments"
- 4. 10 CFR 50.71, "Maintenance of Records, Making of Reports" 5. 10 CFR 50.90, "Application for Amendment of License or Construction Permit"
1.3 DEFINITIONS
AND/OR ACRONYMS 10 CFR 50.59 REVIEW - A written regulatory evaluation which provides the basis for the determination that a change does, or does not, require NRC approval pursuant to 10 CFR 50.59. The scope of the evaluation should be commensurate with the potential
safety significance of the change, but must address the relevant safety concerns included in the Safety Analysis Report and other owner controlled documents. The depth of the evaluation must be sufficient to determine whether or not NRC approval is required prior to implementation. Depending upon the significance of the change, the evaluation may be brief; however, a simple statement of conclusion is not sufficient.
TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 3 of 15 Revision QC-TRM-05-001 Technical Requirements Manual EDITORIAL CHANGE - Editorial changes include correction of
punctuation, insignificant word or title changes, style or format changes, typographical errors, or correction of reference errors
that do not change the intent, outcome, results, functions, processes, responsibilities, or performance requirements of the item being changed. Changes in numerical values shall not be considered as editorial changes. Editorial changes do not
constitute a change to the TRM and therefore do not require
further 10 CFR 50.59 Reviews. If the full scope of this proposed change is encompassed by one or more of the below, then the change is considered editorial.
- Rewording or format changes that do not result in changing actions to be accomplished. - Deletion of cycle-specific information that is no longer applicable. - Addition of clarifying information, such as: - Spelling, grammar, or punctuation changes - Changes to references - Name or title references
1.4 PROGRAM
DESCRIPTION
- 1. A Licensee may make changes to the TRM without prior NRC approval provided the changes do not require NRC approval
pursuant to 10 CFR 50.59.
- 2. Changes that require NRC approval pursuant to 10 CFR 50.59 shall be submitted to the NRC pursuant to 10 CFR 50.90 and
reviewed and approved by the NRC prior to implementation.
- 3. The TRM is part of the Updated Final Safety Analysis Report (UFSAR) by reference and shall be maintained consistent with the remainder of the UFSAR.
- 4. If a change to the TRM is not consistent with the remainder of the UFSAR, then the cognizant Engineer shall prepare and
submit a UFSAR Change Package when the TRM Change Request is submitted to Regulatory Assurance (RA) for processing.
- 5. Changes to the TRM that do not require prior NRC approval shall be provided to the NRC on a frequency consistent with
10 CFR 50.71(e), as modified by approved exemptions.
TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 4 of 15 Revision QC-TRM-05-001 Technical Requirements Manual 6. Any change to a Station's TRM shall be transmitted, via Attachment D, "Technical Requirements Manual Change Applicability Review Form," to the Regulatory Assurance
Managers (RAMs) at each of the other Stations. The RAM will review the TRM change for applicability at their respective Station and document their review on Attachment D.
- 7. TRM changes associated with a Technical Specifications (TS)
Amendment shall be implemented consistent with the implementation requirements of the TS Amendment.
- 8. RA is responsible for the control and distribution of the TRM. In order to prevent distribution errors (i.e.,
omissions or duplications), RA shall maintain the master TRM distribution list.
1.5 PROGRAM
IMPLEMENTATION
- 1. TRM Change Requestor identifies the need for a revision to the TRM and notifies the RA Licensing Engineer (i.e.,
hereafter referred to as RA LE). A TRM change can be
initiated through any Stations' RA. TRM Change Requestor notifies their counterparts on the need for a change.
- 3. RA LE assigns a TRM Change Request Number (CR #) and records on Attachment B, "Technical Requirements Manual Change
Request Log." The CR # should be a sequential number beginning with the last two digits of the year (e.g., 00-00#). 4. RA LE drafts TRM changes considering format, rules of usage, and technical adequacy, and notifies RAMs at each of the
other Stations by transmitting Attachment D, "Technical Requirements Manual Change Applicability Review Form."
TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 5 of 15 Revision QC-TRM-05-001 Technical Requirements Manual
- 5. RA LE makes an electronic version of the proposed TRM changes available in a working directory for use in the preparation of the 10 CFR 50.59 REVIEW and Station Qualified Review (SQR) process. The RA LE shall ensure that the master electronic TRM files are revised per step 12 below upon
receiving SQR approval. The Revision number in the footer should be a sequential number (i.e., 1, 2, etc.).
- NOTE If the TRM changes are applicable to more than one Station, the following steps should be performed concurrently for each Station.
- 6. TRM Change Requestor provides a 10 CFR 50.59 REVIEW for the TRM changes in accordance with appropriate plant procedures.
An exception to this requirement applies when the changes are being requested in order to reflect an approved NRC Safety Evaluation (SE) associated with a site specific Operating License or TS change. The NRC SE is sufficient to support the changes provided it has been determined that the
changes are consistent with and entirely bounded by the NRC SE. A 10 CFR 50.59 REVIEW shall be performed for TRM changes that reflect generic industry approval by an NRC SE to determine site specific applicability. A 10 CFR 50.59 REVIEW is not required for an EDITORIAL CHANGE.
- 7. TRM Change Requestor completes Attachment A, "Technical Requirements Manual Change Request Form," as follows:
- a. Identifies the affected sections, and includes a copy of the proposed TRM changes;
- b. Briefly summarizes the changes including the TLCO, Action, Surveillance Requirement, or Bases (if
applicable) to which the changes apply;
- c. Briefly summarizes the reason for the changes and attaches all supporting documentation;
- d. Identifies any schedule requirements and proposed implementation date that apply (i.e., describe any
time limitations that might apply which would require expedited processing). If the changes are outage
related, then checks "yes" and lists the applicable outage identifier;
TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 6 of 15 Revision QC-TRM-05-001 Technical Requirements Manual e. Identifies any known implementation requirements such as procedure changes, UFSAR changes, Passport changes, Reportability Manual revisions, pre-implementation training requirements, etc.;
- f. If a 10 CFR 50.59 REVIEW was prepared to support the TRM changes, the Requestor then checks the appropriate
box, lists the associated 10 CFR 50.59 REVIEW Number, and attaches the original;
- g. If the changes to the TRM are the result of an approved NRC SE associated with a site specific Operating License or TS change and the scope of the changes determined to be consistent with and entirely
bounded by the NRC SE, then the Requestor checks the
appropriate box and attaches a copy;
- h. If the changes to the TRM are EDITORIAL CHANGES, then the Requestor checks the appropriate box and no 10 CFR
50.59 REVIEW is required;
- i. Signs and dates as Requestor and identifies the originating department;
- j. Obtains approval to proceed from Department Supervisor (or designee); and
- k. Returns Attachment A to the RA LE.
- 8. RA LE reviews the TRM Change Request Form, including supporting documentation, and documents the review by
signing Attachment A. The review verifies that the following information or documentation is included:
- a. Completed 10 CFR 50.59 REVIEW. If the changes are related to an approved NRC SE associated with a site specific Operating License or TS change and determined to be entirely bounded by the NRC SE, then only a copy of the SE is required to be attached and no 10 CFR 50.59 REVIEW is required. A 10 CFR 50.59 REVIEW is not required for an EDITORIAL CHANGE;
- b. Identification of known documents requiring revisions; and TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 7 of 15 Revision QC-TRM-05-001 Technical Requirements Manual c. Completed UFSAR Change Request with supporting documentation, in accordance with appropriate plant procedures, if applicable.
- 9. If the TRM change is not an EDITORIAL CHANGE, the RA LE/TRM Change Requestor obtains SQR approval of the TRM change by performing the following:
completed 10 CFR 50.59 REVIEW or NRC SE) and the revised TRM pages. Attachment A is provided for the purpose of reviewing and finalizing the implementation requirements and ensuring the necessary actions have been initiated. RA LE shall assign Action Tracking (AT) items, as necessary, to track implementation requirements;
- b. TRM Change Requestor submits the TRM Change SQR package to the SQR Committee members for a preliminary review. The SQR composition shall include RA and Operating Departments in all cases; and
- c. TRM Change Requestor resolves preliminary review comments and finalizes the TRM Change SQR package.
- 10. The RAM shall determine the need for Plant Operations Review Committee (PORC) approval. The need for PORC approval shall
be documented on Attachment A.
- 12. After approval of the TRM changes by SQR/PORC, RA LE ensures that the controlled master electronic files are updated.
- 13. RA LE completes Attachment C, "Technical Requirements Manual Change Instruction Form," as follows:
TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 8 of 15 Revision QC-TRM-05-001 Technical Requirements Manual a. Indicates the effective date of the TRM changes consistent with the SQR/PORC approval or TS amendment required implementation date. If the TRM change is a result of a TS Amendment, the update shall be implemented consistent with the implementation requirements of the TS Amendment. Otherwise, the update must be implemented by the date indicated on Attachment C;
- b. Lists each page to be removed and inserted, including the Affected Page List; and
- c. Provides the updated master file directory for updating Electronic Document Management System (EDMS), if applicable.
- 1. TRM Change Instruction Form (Attachment C);
- 2. Revised Affected Page List; and
- 3. Revised TRM pages.
One RA LE shall assemble and approve the TRM Change Package for distribution and a second RA LE shall perform a peer
check to verify completeness of the TRM Change Package.
- 15. After verifying that SQR/PORC approval of the TRM changes has been obtained and that all AT items assigned to track
implementation requirements have been completed, RA LE forwards the TRM Change Package to Station Records Management as notification of the need to update the onsite TRM controlled copies and EDMS, if applicable.
- 16. RA LE also forwards the TRM Change Package to Cantera Licensing (CL) Records Management as notification of the need to update the offsite (CL) TRM controlled copies and to transmit updates to the offsite (non-CL) TRM controlled copies.
TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 9 of 15 Revision QC-TRM-05-001 Technical Requirements Manual 17. Upon completion of updating the onsite TRM controlled copies and EDMS (if applicable), Station Records Management Supervisor signs and dates Attachment C and returns Attachment C to the RA LE.
- 18. Upon completion of updating the offsite (CL) TRM controlled copies and transmitting updates to the offsite (non-CL) TRM controlled copies, CL Records Management signs and dates Attachment C and returns Attachment C to the RA LE.
- a. 10 CFR 50.59 REVIEW Number;
- b. SQR Number, if applicable;
- c. SQR Approval Date; and
- d. TRM change implementation date.
- 20. RA LE ensures that the documentation required to be maintained as a quality record is provided to Station Records Management for the purpose of record retention.
1.6 ACCEPTANCE
CRITERIA Not applicable.
1.7 LCOARS/COMPENSATORY MEASURES An Issue Report may need to be generated to provide proper tracking and resolution of noted problems associated with the implementation of this Program.
The RAM will be responsible for ensuring that Program failures have been resolved.
TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 10 of 15 Revision QC-TRM-05-001 Technical Requirements Manual 1.8 REPORTING REQUIREMENTS
- NOTE TRM changes requiring prior NRC approval shall be submitted in accordance with Reference 5.
TRM changes not requiring prior NRC approval, as described in Section 1.4 of this Program, shall be submitted to the NRC in accordance with 10 CFR 50.71(e).
1.9 CHANGE
CONTROL Changes to this Program, other than EDITORIAL CHANGES, shall include a 10 CFR 50.59 REVIEW and a SQR. The SQR composition shall include RA Department in all cases. For a change to this Program, PORC approval from all Stations is required. The concurrence shall be that the other Stations are implementing the same changes or
that the changes have been reviewed and determined not to be applicable to the other Stations.
TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 11 of 15 Revision QC-TRM-05-001 Technical Requirements Manual ATTACHMENT A TECHNICAL REQUIREMENTS MANUAL CHANGE REQUEST FORM
- 1. Change Request #: _____________ Affected TRM Section(s): _________________________
- 2. Description of changes: _________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
- 3. Reason for changes (attach all supporting documentation): ____________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
- 4. Schedule Requirements: Outage Related (check one) No Yes, Outage # ___________ Other (explain) ___________________________________________________________________
- 5. Implementation Requirements (attach additional pages, as necessary):
Identify the impact of the changes on the following: Affected N/A UFSAR ______________________________________________________________
TS _________________________________________________________________
TS Bases ___________________________________________________________
NRC Safety Evaluation _____________________________________________
Fire Protection Report _____________________________________________
NRC Commitments ____________________________________________________
Vendor Documentation _______________________________________________
Special Permits/Licenses ___________________________________________
Procedures _________________________________________________________
Environmental Qualification ________________________________________
Design Basis Documentation _________________________________________
Engineering Calculations ___________________________________________
Drawings/Prints ____________________________________________________
PRA Information ____________________________________________________
Programs ___________________________________________________________
Reportability Manual _______________________________________________
QA Topical Report __________________________________________________
Passport ___________________________________________________________
Pre-Implementation Training Required _______________________________
Maintenance Rule ___________________________________________________
Offsite Dose Calculation Manual ____________________________________
Other ______________________________________________________________
- 6. Check one:
10 CFR 50.59 REVIEW Attached, 10 CFR 50.59 REVIEW #:_________________________
NRC SE Attached, Changes consistent with and entirely bounded by NRC SE EDITORIAL CHANGE, No 10 CFR 50.59 REVIEW required
- 7. Requestor: ______________________/______________________/________________________ (Signature) (Date) (Department)
- 8. Requesting Supervisor Approval: _______________________/________________________ (Signature) (Date)
- 9. PORC Approval Required: Yes No
- 10. Licensing Engineer Review: _______________________/________________________
(Signature) (Date)
TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 12 of 15 Revision QC-TRM-05-001 Technical Requirements Manual ATTACHMENT B TECHNICAL REQUIREMENTS MANUAL CHANGE REQUEST LOG CR # Brief Description of Changes Affected Section(s) 10 CFR 50.59 REVIEW # SQR # SQR Approval Date Implemented Date TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 13 of 15 Revision QC-TRM-05-001 Technical Requirements Manual ATTACHMENT C TECHNICAL REQUIREMENTS MANUAL CHANGE INSTRUCTION FORM FOR ONSITE/OFFSITE DISTRIBUTION AND FOR UPDATING EDMS
Braidwood/Byron/Dresden/LaSalle/QC (circle one) TRM Revision # ______
NOTE: This change is effective as of _____________________________ and shall be implemented by __________ . (SQR/PORC or Amendment Implementation Date) (Date)
Approved for distribution: ___________________________________/_____________ (RA LE Signature) (Date)
Verified: ___________________________________/_____________ (RA LE Signature) (Date)
REMOVE Section REMOVE Page INSERT Section INSERT Page UPDATE EDMS Section UPDATE EDMS Page Affected
Page List All Affected Page List All N/A N/A
TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 14 of 15 Revision QC-TRM-05-001 Technical Requirements Manual ATTACHMENT C TECHNICAL REQUIREMENTS MANUAL CHANGE INSTRUCTION FORM FOR ONSITE/OFFSITE DISTRIBUTION AND FOR UPDATING EDMS
Braidwood/Byron/Dresden/LaSalle/QC (circle one) TRM Revision # ______
___________________________________________________________________________________________
Station Records Management:
Onsite Distribution Completed: ______________________________/___________________
(Station Records Mgmt. Supr.) (Date)
EDMS Update Completed: ______________________________/___________________ (Station Records Mgmt. Supr.) (Date)
- Return this sheet to: Regulatory Assurance Braidwood/Byron/Dresden/LaSalle/QC (circle one) Station
___________________________________________________________________________________________
CL Records Management:
Offsite (CL) Distribution Completed: ___________________________/____________________ (CL Records Mgmt.) (Date)
Offsite (non-CL) Distribution Transmitted: ___________________________/____________________ (CL Records Mgmt.) (Date)
- Return this sheet to: Regulatory Assurance Braidwood/Byron/Dresden/LaSalle/QC (circle one) Station
___________________________________________________________________________________________
Offsite (non-CL) Controlled Copy Holders:
Offsite (non-CL) Distribution Completed: ___________________________/____________________ (Signature) (Date)
- Return this sheet to: EXELON GENERATION COMPANY, LLC LICENSING AND REGULATORY AFFAIRS DEPARTMENT 4300 WINFIELD ROAD WARRENVILLE, IL 60555
TRM TRM Control Program Appendix G Quad Cities Units 1 & 2 15 of 15 Revision QC-TRM-05-001 Technical Requirements Manual ATTACHMENT D TECHNICAL REQUIREMENTS MANUAL CHANGE APPLICABILITY REVIEW FORM Any change to a Station's Technical Requirements Manual (TRM) shall be transmitted to the
Regulatory Assurance Managers (RAMs) at each of the other Stations. The RAM will review the TRM change for applicability at their respective Station. Review of applicability shall be documented on this Attachment and forwarded to the Regulatory Assurance Licensing Engineer(s)
at the Station(s) making the change.
Braidwood/Byron/Dresden/LaSalle/QC (circle one)
TRM Section(s)/Title(s): __________________________________________________________________
Description of the change: _________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
Braidwood RAM Review: ________________________/_______________ (Signature) (Date)
Change Applicable: Yes No Byron RAM Review: ________________________/_______________ (Signature) (Date)
Change Applicable: Yes No Dresden RAM Review: ________________________/_______________
(Signature) (Date)
Change Applicable: Yes No LaSalle RAM Review: ________________________/_______________ (Signature) (Date)
Change Applicable: Yes No QC RAM Review: ________________________/_______________ (Signature) (Date)
Change Applicable: Yes No
- Return this sheet to: Regulatory Assurance Braidwood/Byron/Dresden/LaSalle/QC (circle one) Station
This Section Intentionally Blank
Technical Requirements Manual Section B 3.1 Not Used