ML20081L163
| ML20081L163 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 06/27/1991 |
| From: | Stols R COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20081L165 | List: |
| References | |
| NUDOCS 9107020420 | |
| Download: ML20081L163 (15) | |
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June 27,1991 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk
Subject:
Quad Cities Nuclear Power Station Units 1 and 2 i App lication for Amendment to Facility Operating i Licenses DPR-29 and DPR-30, Appendix A, Technical i Specifications !
Technical Specification Upgrade Program NRG.RocketNosJh25.4_and 50-265 l Dr. Murley:
In 1991, Quad Cities Station initiated a formal program to enMnce the Station's performance in various aspects of plant operation. The Performance Enhancement Program (PEP) was developed by assessing existing improvement plans, identifying potential weaknesses and prioritizing improvement actions.
Necessary improvements to the Technical Specifications were identified as one of the Station top priority issue. Details of the goal and methodology for the Technical i Specification Upgrade Program are provided in the Executive Summary section of the l
proposed amendment. The Program has been discussed with members of the NRR staff.
l Pursuant to 10 CFR 50.90, Commonwealth Edison proposes to amend Appendix A, Technical Specifications to Facility Operating Licenses DPR-29 and DPR-30. The proposed amendment reflects Commonwealth Edison's efforts to upgrade existing Technical Specification Sections 1.1/2.1, " Fuel Cladding Integrity" and l 1.2/2.2, " Reactor Coolant System" An overall description of the proposed amendment is also included in the Executive Summary.
The proposed amendment request for each Technical Specification section is provided as follows:
- 1. An Executive Su.nmary of the Technical Specification Upgrade Program and the proposed amendment;
- 2. A summary of the changes;
- 3. A detailed description of the changes;
- 4. The proposed Technical Specification pages with the requested changes;
- 5. The existing Technical Specification pages for DPR-29, are marked-up :o reflect thc appropriate changes to the existing Technical Specifications;
- 6. Commonwealth Edison's evaluation pursuant to 10 CFR 50.92(c) and 10 CFR 51.21; and,
- 7. The technical differences between the existing Unit 1 and Unit 2 Technical Specifications.
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Dr. Thomas E. Murley June 27,1991 The proposed amendment has been reviewed and approved by Commonwealth Edison's on-site and ofbsite review in accordance with Company procedures.
The Technical Specification Upgrade Program proposes changes to each section of the existing Technical Specifications. As such, Commonwealth Eoison rec uests that the proposed amendments be ap 3 roved and issued as one document rat 1er than as Individual sections. All proposecI changes to the Technical Specifications which are developed under this program will be submitted to the Commission by no later than September 30,1991. Commonwealth Edison respectfully requests the NRC's approval of the upgraded Technical Specifications by July 1,1992.
To the best of my knowledge and belief, the statements contained are true and correct. In some respects, these statements are not based on my personal knowledge but obtained information furnished by other Commonwealth Edison employees and consultants. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Commonwealth Edison is notifying the State of Illinois of this application for amendment by transmitting a copy of this letter and its attachments to the designated State Official.
Please direct any questions concerning this proposed amendment to R. Stols at 708/515-7283.
Ve t uly yogs, W
Rita Stols Nuclear Licensing Administrator Enclosure (A): Proposed Amendment to Technical Specification Section 1.1/2.1
" Fuel Cladding Integrity" and Section 1.1/2.2 " Reactor Coolant System" cc: A.B. Davis, Regional Administrator
- L.N. Olshan, Project Manager T.E. Taylor, Senior Resident inspector Illinois Department of Nuclear Safety State of , County of Signed before me on thisJI# day of _fffzg"_,1991. , s
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1 QUAD CITIES NUCLEAR POWER STATION i
TECHNICAL SPECIFICATION UPGRADE PROGRAM
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PROPOSED AMENDMENTS SECTION 1.1/2.1 " Fuel Cladding Integrity" SECTION 1.2/2.2 " Reactor Coolant System" m m W e 6 MM W
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l EXECUTIVE
SUMMARY
Proposed Changes to TS 1.1/ 2.1 and 1.2 / 2.2
' FUEL CLADDING INTEGRITY' and
O a EXECUTIVE EVEMARY QUAD CITIES TECHNICAL SPECIFICATION UPGRADE PROGRAM The Quad Cities Technical Specification Upgrade Program was conceptualized in response to lessons learned from the Dresden Diagnostic Evaluation Team inspection and the frequent need for Technical Specification interpretations. A comparison of the existing Quad Cities Technical Specification and, Standard Technical Specifications and later operating plants' Technical Specification provisions was conducted to identify potential improvements in clarifying requirements and to identify requirements which are no longer consistent with current industry practices.
The comparison review identified approximately one-hundred and fifty suggested improvements. The Technical Specification Upgrade Program was not intended to be a complete adoption of the Standard Technical Specifications.
Overall, the Quad Cities custom Technical Specifications provide for safe operation of the plant and, therefore, only a upgrade was deemed appropriate.
The comparison study revealed a mix of recormended upgrades which included the relaxation of certain existing Technical Specification requirements, the addition of surveillances, the removal of allowances which would no longer be allowed under new plant licensing, and better definition of appropriate action requirements in the event a Limiting Condition for Operation cannot be met. The Technical Specification Upgrade Program elso implements NRC recommended line item improvements to the Technical Specifications which were issued under Generic Letters.
In response to an NRC recommendation, the Unit 1 and Unit 2 Technical Specifications are combined into one document. To accomplish the combination of the Units' Technical Specifications, a comparison of the Unit 1 and 2 Technical Specifications was performed to identify any technical differences. The technical differences are identified in the proposed amendment package for each section.
The Technical Specification Upgrade Program was identified as a Station top priority during the development of Quad Cities Station's Performance Enhancement Program (PEP). The Technical Specification Upgrade Program's goal is to provide a better tool to Station personnel to implement their responsibilities and to ensure Quad Cities Station is operated in accordance with current industry practices. The upgraded specifications provide for more safe and reliable operation of the plant. The program improves the operator's '
ability to use the Technical Specifications by more clearly defining Limiting Conditions for Operations and required actions. The most significant improvement to the specifications is the addition of equipment operability requirements during shutdown conditions.
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EXECUTIVE'BUMMABX (co_ntinued) l 1
Propose 3-Changes to Technical Specification' l Section 1.1/2.1 " Fuel Cladding Integrity" and Section 1.2/2.2 " Reactor Coolant System" l The current Quad Cities Technical Specifications contain Applicability and Objective statements at the beginning of l most sections. The proposed amendment will delete the l
" Objective" and integrates appropriate applicability '
statements within the Specifications. This provides a clarification of the intended re@irements and actions which i
are required when the specification cannot be met. I
, The proposed amendment does not alter the intent of the ,
i existing setpoints or accident assumptions and follow 1 existing requirements associated with the operability and 1 Action statements at other operating boiling water reactors, j l
The prohibition of operating in the natural circulation ,
flow mode from the. Limiting Safety System Setting to a
-Limiting Condition for Operations under proposed section I
!. 3.6.J - (which is associated with Recirculation Pump flow-l requirements) provides for better operator reference. Also, the proposed amendment-defines the reactor low water level scram setting as. greater than or equal to 144 inches above !
the top of the active fuel. The existing Technical '
Specifications' requires the setting at 144 inches; therefore,
.the proposed amendment provides the additional clarification, in-the conservative direction.
I
I
SUMMARY
OF CHANGES PROPOSED TS 1.1/ 2.1 and 1,2 / 2,2
' FUEL CLADDING INTEGRITY' and
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SUMMARY
OE CHANGES PROPOSED SPECIFICATION 1.1/2.1 AND 1.2/2.2 FUEL CLADDING INTEGRITY / REACTOR COOLANT SYSTEM This section contains proposed changes to Quad Cities Units 1 and 2 Technical Specification Sections 1.1/2.1 and 1.2/2.2. Some of the changes proposed are made to irnrove readability and usability of the present technical specifications by incorporating a format similar to the Standard Technical Specifications. The specific changes are described below.
Item 1:
Paces 1.1/2.1-1 thrgngh 1.1/2.1-5, DPR-29
- a. Delete the present Applicability and Objective sections at the beginning of Section 1.1/2.1. The Applicability statement is being included after the Safety Limit or Limiting Safety System Setting statement in each individual specification.
- b. The present title for Safety Limit 1.1.A is changed to Thermal Power, High Pressure and High Flow similar to STS provisions.
Safety Limit, Applicability and Action provisions are added similar to STS provisions,
- c. The present title for Safety Limit 1.1.B is changed to Thermal Power, Low Pressure or Low Flow similar to STS provisions.
Safety Limit, Applicability and Action provisions are added similar to STS provisions.
- d. Present Safety Limit Specification 1.1.C is changed by adding Applicability and Action provisions siullar to STS provisions.
- e. The present title for Safety Limit 1.1.D is changed to Reactor Vessel Water Level. Safety Limit, Applicability, and Action provisions are added similar to STS provisions. Present
- footnote defining top of active fuel is incorporated into the proposed Safety Limit requirement.
- f. Limiting Safety System Setting Specification 2.1.A is changed by adding Applicability and Action provisions similar to STS provisions. Present reguirement 2.1.A.4 prohibiting operation in the natural circulation flow mode while in Startup or Run Modes is moved to proposed Specification 3.6.J on Recirculation Pump Flow Limitations.
- g. Present Limiting Safety System Setting Specification 2.1.B is changed by adding Applicability and Action provisions similar to STS provisions.
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.h. Present Specification 2.1.C is changed to incorporate the remaining Reactor Protection System Limiting Safety System Settings of present Specifications 2.1.C, 2.1.E, 2.1.F, 2.1.G, 2.1.I and 2.1.J. Limiting Safety System Setting, Applicability and Action provisions are added similar to l STS provisions. Present
- footnote defining top of active l fuel is incorporated into the proposed Limiting Safety i System Setting for Specifications 2.1.C. Present reactor low 1 water level scram setting of 144 inches above the top of active fuel is changed to 2 144 inches above the top of active fuel.
- i. Present Specification 2.1.D is changed b Reactor Low Water Level ECCS Initiation.yLimiting adding the title, Safety System Setting, Applicability and Action provisions are added similar to STS provisions. Present
- footnote defining top of active fuel is incorporated into the proposed Limiting Safety l System Setting for Specification 2.1.D.
- j. Proposed Specification 2.1.E is formed from present j Specification 2.1.H. The proposed title for Specification 1 2.1.E is Main Steamline Low Pressure Isolation with Limiting 1 Safety System setting, Applicability and Action provisions I added similar to STS provisions.
Item 2:
Paces B 1.1/2.1-1 throuch B 1.1/2.1-12, DPR-29 l
The changes to the Bases for Specifications 1.1 and 2.1 are i proposed to reflect the proposed changes to the respective Specifications as described in Item-1 above. 1 Item 3:
Ficules 2.1-1. 2.1-2. and 221-3, DPR-22 Present Figure 2.1-2 was previously deleted. The remaining two Figures are renumbered as Figures 2.1-1 and 2.1-2 and are located immediately after the Technical Specifications and before the Bases for Section 1.1/2.1.
Item 4:
Pace 1.2/2.2-1. DPR-29
- a. Delete the present Applicability and Objective sections at the beginning of Section 1.2/2.2. The Applicability section is being added to each individual specification similar to STS guidelines,
- b. Present Specification 1.2.A is changed by adding th1 title, l Reactor Coolant System Pressure Setting. Safety Limit, Applicability and Action requirements are added similar to STS I
1 I
s e provisions,
- c. Present Specification 2.2.A is changed by adding the title, Reactor Coolant System High-Pressure Scram Setting.
Limiting Safety System Setting, Applicability and Action provisions are added similar to STS provisions.
- d. Present Specification 2.2.5 is changed by adding the title, Primary System Safety Valve Settings. Present Limiting Safety System Settings are retained. Applicability and Action provisions are added to reference the requirements of Specification 3.6 G.
Item 5:
Pages B 1.2/2.2-1 throuch B 1.2/2.2-3, DPR-29 The changes proposed to the Bases for Section 1.2/2.2 are made to capitalize terms defined in proposed Section 1.0, Definitions.
o o DESCRIPTION OF CHANGES PROPO3ED TS 1.1/ 2.1 and 1.2 / 2.2
' FUEL CLADDING INTEGRITY' and
_o o DESCRlPTION QZ ERQEQREp MiEHplEET BEQM ET ,
PROPOSED SPECIFICATION 1.1/2.1 AND 1.2/2.2 FUEL CLADDING INTEGRITY / REACTOR COOLANT SYSTEM The changes proposed in this amendment request for Sections 1.1/2.1 and 1.2/2.2 of the Quad Cities Technical Specifications are made to improve the understanding and usability of the preserr requirements and to include some improvements from later operating BWR plants.
An item by item description of the proposed changes requested is provided below. The Summary of Changes section can be referred to in order to reference back to a given change and its affected pages.
Ite.m 1 The present Quad Cities Technical Specifications contain Applicability and objective statements at the beginning of most sections. These statements are generic in nature and do not provide any useful information to the user of the technical specifications. The proposed change will delete the Objective statement and provide Applicability statements within each specification similar to the STS. The proposed Applicability statement to be included in each specification will include the Reactor Operational Modes or other conditions for which the LCO must be satisfied.
The changes to Section 1.1/2.1 include adding titles to specifications and changing to an'STS type of format with Applicability and Action provisions. The two column layout has been utilized at Quad Cities since initial licensing of the plant and is; preferred by the plant over the single column STS layout.
The changes to present Safety Limit 1.1.A follow STS guidelines.
Y The title is changed to " Thermal Power, High Pressure and High Flow" and the present safety limit is reworded without changing present_ technical requirements. The proposed Applicability is Operational Modes 1 and 2 to include those reactor conditions where the Safety Limit can apply. The proposed Action
,_ requirements fcllow STS guidelines by allowing 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to reach L Hot Shutdown if the Safety Limit is violated and by reguiring
- compliance with Specification 6.4 for reports and prohibition of return to power without NRC approval.
The croposed changes to present Safety Limit 1.1.B are similar to l those described for Safety Limit 1.1.A above with the title being changed to " Thermal Power, Low Pressure or Low Flow" to match STS l guidelines.
l The proposed changes to present Safety Limit 1.1.C for Power l
l
O b Transients include the addition of Applicability and Action provisions similar to STS provisions. The proposed Applicability of Operational Modes 1 and 2 includes those reactor conditions where the Safety Limit protection is needed. The proposed Action provisions ensure that if a scram setpoint (Specification 2.1.A) is exceeded and a scram does not occur, that a manual scram is initiated and Hot Shutdown is reached within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and the provisions of Specification 6.4 are followed for reports and for prohibition of restart without NRC permission.
The changes to present Safety Limit 2.1.D on Reactor Vessel Water Level (Shutdown Condition) include incorporating the
- footnote defining top of active fuel into the Safety Limit and the addition of Applicability and Action provisions similar to STS guidelines.
The proposed Applicability of operational Modes 3, 4 and 5 include all shutdown conditions. The proposed Actions if reactor water level is less than 12 inches above top of active fuel include ECCS manual initiation and complying with the provisions of Specification 6.4 as discussed above.
The proposed changes to present Limiting Safety System Setting 2.1.A, Neutron Flux Trip Setting, include the addition of Applicability and Action provisions similar to STS guidelines.
The proposed Applicability provision refers to Table 3.1-1 for Applica0le operational Modes and deletes reference to Modes in present Specification 2.1.A. The proposed Action provisions require that with a setting less conservative than specified, the channel be declared inoperable and the Actions of Specification 3.1.A for the Reactor Protection System be met until the channel is restored. Present requirement 2.1.A.4 prohibits operation in the natural circulation mode when the reactor mode switch is in the Startup or Run positions. Specification 2.1.A.4 is not a Neutron Flux Trip Setting and is being moved to Technical Specification Section 3.6.J on Recirculation Pump Flow Requirements.
The proposed changes to present Limiting Safety System Setting 2.1.B, APRM Rod Block Setting, include the addition'of Applicability and Action provisions similar to STS guidelines.
The proposed Applicability provision refers to Table 3.2-3 for Applicable Operational Modes. The proposed Action provisions require that with a setting less conservative than specified, the channel be declared inoperable and the Actions of Specification 3.2.C be met until the channel is restored.
Present Specifications 2.1.C, 2.1.E, 2.1.F, 2.1.G, 2.1.I and 2.1.J contain Limiting Safety System settings that produce scram signals in the Reactor Protection System. These Specifications are combined by rewriting present Specification 2.1.C and by using STS guidelines. The proposed Applicability provision refers to Table 3.1-1 for Applicable Operational Modes for the Reactor Protection System Instrumentation. The proposed Action provisions are similar to those for Specification 2.1.A for Neutron Flux Trip Settings within the Reactor Protection System. Present
- footnote I
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i . w defining top of active fuel is incorporated into the Limiting Safety System Setting for the reactor low water level scram setting. The present low water level scram setting is stated as 144 inches above the top of active fuel at normal operating conditions in Specification 2.1.C. This present low water level scram setting should be stated as 2 144 inches above the top of active fuel at normal operating conditions in order to match the same setting as stated in Section 3.1/4.1, Reactor Protection System. Using the 2 144 inch setting provides necessary conservatism in the setting and allows for instrument drif t and accuracy. ,
Present Specification 2.1.D is changed by adding the title,
" Reactor Low Water Level ECCS Initiation". Other changes also follow STS guidelines by adding an Applicability section that refers to Table 3.2-2 for Applicable Operational Modes and an Action section that requires compliance with the provisions of Specification 3.2.B if the reactor low water level ECCS setpoint is le .s conservative than specified. As in other items above, the preso t
- footnote is incorporated into the Limiting Safety System Setti i section.
P?ene : Specification 2.1.H is renumbered to 2.1.E and changes are 9roposed to add the title " Main Steamline Low Pressure Isolation" and to rewrite the Applicability and Action provisions following STS guidelines for Limiting Safety System Settings. The proposed Applicability section refers to Table 3.2-1 for Applicable Operational Modes for Isolation Instrumentation. The proposed Action refers to Specification 3.2.A requirements if the main steamline low pressure setpoint is less conservative than specified.
Item 2 The changes proposed in Item 1 above require that the Bases for Section 1.1/2.1 be rewritten to reflect the new titles and-reordering of the Specifications. These changes are administrative in nature and are not intended to change the technical content.
Item 3 This item involves the renumbering and relocation of present Figures 2.1-1 and 2.1-3. Present Figure 2.1-2 has been previously deleted and this page is being removed from the technical specifications. Present Figures 2.1-1 and 2.1-3 are renumbered as 2.1-1 and 2.1-2. The relocation of the Figures from the end of Section 1.1/2.1 to before the Bases reflects the greater importance of the material in the Figures ever the Bases material.
Item 4 The changes proposed for Section 1.2/2.2 are similar to changes proposed in Item 1 above for Section 1.1/2.1. The present
o :u Applicability and Objective sections at the beginning of Section 1.2/2.2 are deleted. The Applicability section is added to each individual specification similar to STS guidelines.
The proposed changes to present Specification 1.2.A adds the title
" Reactor Coolant System Pressure" and adds Applicability and Action provisions similar to STS guidelines. The present applicability of at any time when irradiated fuel is in the reactor vessel is replaced with Operational Modes 1, 2, 3 and 4.
The proposed Operational Modes cover all situations where the reactor vessel could become pressurized since Operational Mode 5 as defined in proposed Table 1.2 is when fuel is in the reactor vessel with the vessel head closure bolts less than fully tensioned or with the head removed. The proposed Action for Safety Limit 1.2 requires that with the reactor coolant system pressure above 1345 psig, the plant be in at least Hot Shutdown with the reactor coolant system pressure less than 1345 psig within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and the provisions of Specification 6.4 be met.
These proposed Actions allow a reasonable time to shutdown the reactor considering the nature of the violation, require proper reports to be made and restrict reactor restart without prior NRC approval.
The proposed changes to present Limiting Safety System Setting 2.2.A include the addition of the title " Reactor Coolant System High-Pressure Scram" and Applicabi}ity and Action sections similar to STS guidelines. The proposed Applicability refers to Tabic 3.1-1 for the Applicable Operational Modes for the Reactor Coolant System High-Pressure Scram. The proposed Action is similar to RPS requirements proposed in Section 2.1 and requires that with the setting less conservative than soecified, the Action statements of Specification 3.1.A be followed until the setpoint is restored.
Present Specification 2.2.B is proposed to be changed by adding the title " Primary System Safety Valve Settings" and Applicability and Action requirements that follow STS guidelines for Limiting Safety System Settings. The proposed Applicability and Action statements refer to Specification 3.6.G for applicable-Operational Modes and action requirements for the Safety-Valves.
Item 1 The changes proposed to the Bases for Section 1.2/2.2 are administrative in nature and involve the capitalization of terms defined in proposed Section 1.0, Definitions.