ML20091L756

Application for Amends to Licenses DPR-29 & DPR-30,changing Spec Ref in TS 3.5.C.2 from 4.5.C.3 to 4.5.C.3.a & in TS 3.5.E.2 from 4.5.E.3 to 4.5.E.3.a,in Regard to HPCI & RCIC Sys

ML20091L756
Person / Time
Site:	Quad Cities
Issue date:	01/21/1992
From:	Schrage J COMMONWEALTH EDISON CO.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20091L761	List: ML20091L756 ML20091L772
References
NUDOCS 9201280219
Download: ML20091L756 (7)

Text

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/ Commonwealth Edloon

/ 1400 Opus Placo i

'. [ Downers Grov3, HHnola 60515  !

January 21, 1992 j

^

Dr. Thomas E. Murley, Director

-Office of Nuclear Reactor Regulation

{;

U.S. Nuclear Regulatory Commission -

Washington, DC 20555 j

' Attn: Document Control Desk j

Subject:

Quad Cities Nuclear Power Station Units 1 and 2 i Application for Amendment to facility Operating Licenses DPR-29 and DPR-30, Appendix A, Technical Specificatiohs l HRC_DockeLNoL_.50-25LanL50-26.5

References:

a). L.N. Olshan letter to T.J. Kovach dated March 8, 1991 i

-b) R.L. Bax (Ceco) letter to USNRC Document Control Desk -

-dated May 28 1991; Licensee Event Report (LER)91-009 l

Dear.Dr. Murley:

Pursuant to 10 CFR 50.90, Commonwealth Edison Company (CECO) proposes  ;

'to amend Appendix A, Technical Specifications of Facility Operating Licenses .

-DPR-29 and DPR-30. The proposed amendment changes a specific action provision

• for the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) systems to a. limited action provision.- The current action .

-provisions do not allow continued plant operation upon successful completion

.of a low pressure flow performance test followed by the subsequent failure of

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a norma 1' operating pressure flow performance test. The flow performance. tests- l are required to b6l performed during start-up following a refuel outage or.an .

outage in which work was performed which directly affected HPCI or RCIC system l operability. Operational experience at Quad Cities Station has demonstrated  !

Lthat these provisions result.in unnecessary. cycling of the reactor while.

. operating.within the heat-upirange, and reduces the ability to determine  !

adequate corrective actions. 'The revised action provi> i would limit the  ;

-applicability ofethe action provision to a fatture of tw low pressure flow. t performance test'.- This revised action provision implements Standard Technical .t

Specification (STS)-provisions which allow a'.14 day allowable outag6 ime, -

o provided that the remaining.high pressure injection and low pressure ECCS- ,

systems are, operable'.

lThe proposed amendment request _is nrovided as follows:

~1.. LAttachment I provides the Safety Evaluation for the proposed  !

amendment;;

2. Attachment 2 provi_ des a summary of the changes; .

t 3.. Attachment 3 provides the proposed Technical Specification pages l( which reflect the proposed changes; f,  ;

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_.1 E', Dr. Thomas [E.1Hurley .2 : . . January 21._1992 v

+ 4i EAttachment 41 describes CECO's evaluation pursuant to 10 CFR j L50.92(c); and,

5. . Attachment 5 provides the Environmental Assessment"for=the proposed ameadment.

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-TheLp'oposed amendment will reduce the--potential for unnecessary

. thermal _ cycling of the-reactor, thereby reducing the liblihood of plant-transients and chu lenges.to safety systems during start-up following a_ refuel outage. 'Ther.efore, CEro respectfully requests the NRC's review and approval 6 'of:this proposed amendment in a time frame which will allow the station to

, ' avold unnece:;sary unit cycllrig following the current refuel outage. This -

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proposed amendment has--bt n reviewed and approved by CECO On-site end Off-site

• review-in accordance with CECO _ procedures.

y To thelbest of my knowledge and belief the statements contained

% therein m ettruc and-. correct. In some respects, these statements are not-based on my person:sl. knowledge but:Upon information received from other Commonwealth '

'idtson:and contractor employees. Such information has been reviewed in accordance with Company practice and I believe it to be reliabte.- 1 s*. _

CECO is notifying the_' State of Illinois of this-appilcation for-

.hmendment by transmitting a copy of the proposed amendment to the designated 1

state official..

1 If thereiare any questions or comments, please direct them-to

! John:L. Schrage.at 708 515-7283.

4 Respectfully, S

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-j ohn Schrage- .

. ,f .N ar-Licensing Administrator b - Stan i

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I Attachment- 1:= Safety Et'aluation:of the Proposed Amendment-Attachment'2: Summary of the Proposed Changes- )

Attachment;.3: ;Prope, sed Technical Specification Pages s Attachment 4:. EvC.7ation Pursuant to 10_CFR 50.92(c)

Attachment 5: -Environmental Assessment for-the_ Proposed Amendment cc:"AC-Bert Davis, Regional' Administrator-RIII X L'N. 01shan, Project Manager-NRR-g <T.E. laylor, Senior Resident Inspector-Quad Cities L

,0ffice of Nuclear Safety-IDNS h..

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i A'ITACIIMENT 1 RAFET( EVALUATION OF Tile PROPOSED AMENDMENT

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1MIR000CU0H Commonwealth Edison Company (CECO) proposes to amend the Technical .

Specifications for Quad Cities Nuclear Power Station (QCNPS) DPR-29 (Unit 1) and DPR-30 (Unit 2). The proposed amenoment would charsge the plant specific action provisions of' Technical Specification (TS) 3.5.C.2 for the.High Pressure Coolant Injection (HPCI)_ system and 3.S.E.2 for the Reactor Core Isolation Ceoling'(RCIC) system to a limited action requirement.

The current provisions of 3.5.C.2 and 3.5.< ' do not allow continued plant operation upon successful completion of the iow prc9sure flow performance

-test,.followed by a subsequent failure of the flow Ierformance test at normal ,

operating pressure._ Recent operational experience at Quad Cities Station

-(start-up operation following the Unit 1 Cycle'11 Refuel OJtoge), has demonstrated that these provisions result in excessive cycling of the reactor while operating within the heat-up range. 1 The proposed amendment would limit the applicability of the action statemerit

.to~the failure of a low pressure flow performance test for the HPCI and-RCIC

-systems. :The action provision for the failure of a flow performance test at normal operating pressure would be oescribed by current specifications 3.5.C.3 and 3.5.E.3-for_the HPCI.ano RCIC systems. These action statements implement the Standard Technical Specification _(STS) provisions.which allow a 14 day allowable-outage time, provided that the remaining high pressure injection and

ow pressure ECCS systems are operable.

MSESl0fLCURREKi_ REQUIREMENT The current operability requirements as Specified by TS 3.5.C.1 and 3.5.E.1 require that the-HPCI-and RCIC systems be operable whenever the reactor pressure is greater than 150 psig and fuel is in the reactor vessel _ The current provisions' satisfy =the core cooling requirements for both small break'

-loss-of-coolant accidents-(HPCI) and non-break reactor Isolation-(RCIC) transient. events with the reactor. pressurized. Below 150 psig reactor-pressure, the low pressure ECCS subsystems can provide sufficient flow to the ireactor pressure vessel.

On March 8, 1991,.the Office of Nuclear Reactor Regulation of the NRC approved Amendment 1_30'and 124 to Appendix A (Technical Specifications) of Facility Operating Licenses DPR-29'and DPR-30 (Reference (a))'. The main. purpose of this amendment was to remove the reauirerv ' .o demonstrate operability of Lother Emergency Core Cooling. Systems (EClu .nen the-High Pressure Coolant Injection (HPCI) or Reactor Core- solation Cooling Systems _(RCIC) are

inoperable. _As part of that amendment, new action statements and associated '

surveillance requirements were added. These describe actions to be taken upon-

-the failure of-flow performance testing requirements during a start-up from a refuel outage or an outage in which work was performcd that directly affected HPCI'or RCIC system operability and these tests. The-action statements (3.5.C.2 and 3.5.E,2) require that if-cither low pressure (reactor vessel pressure of 150 to 325 psig);or high pressure (reactor vessel pressure of 920 to 1005 psig) flow performance testing requirements cannot be met for either the HPCI or RCIC system, then that system shall b, declared inoperable: an orderly shutdown shall be initiated; and, reactor pressure shall be reduced to less than'150 psig within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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DASES_f0R _CURKE N L R50VI REMENL(con t ' d )

The action requirements (TS 3.5.C.2 and 3.5.E.2) and associated flow performance tests (T5 4.5.C.3 and 4.5.E.3), which were previously added by License Amendments 130 and 124, adopted a modified version of STS and BWR industry action provisions. These provisions require the performance of two (2) flow rate tests for HPCI (RCIC), i.e. one test every 92 days and another under certain start-up conditions. The previous method of testing allowed an acceptance criteria if one point on the pump curve was achieved against a system head pressure corresponding to a reactor vessel pressure of 150 psig to 1150 psig.

DESCRI PT ION _0EIH E _ _M E ED_10_ Ct1ANGE _ IllLCURRE NL REQU I REME NI S Flow performance tests for the HPCI and RCIC systems are currently performed at two levels of reactor pressure. The current low pressure test is required to be performed within twelve (12) hours of achieving the required reactor pressure and prior to exceeding 325 psig. The test at normal operating pressure is required to be performed within twelve (12) hours of achieving reactor vessel pressures in the normal operating range of 920 to 1005 psig.

Given the successful completion of a low pressure flow performance test for the HPCI and RCIC systems (TS 4.5.C.3.a and 4.5.E.3.a) during start-up, the normal operating pressure flow per*ormance test (TS 4.5.C 3.b and 4.5.E.3.b) cannot be reasonably ar.ticipated to fall before the unit has achieved normal operating pressure. Operational experience at Quad Cities Station (start-up operation following the Unit 1 Cycle 11 Refuel Outage) has demonstrated that the current provisions of T5 3.5.C.2 and 3.5.E.2 have resulted in unnecessary

.ycling of the reactor through the heat-up range and a reduction in the ability to determine adequate corrective maintenance actions (Reference (b)).

The potential for unnecessary cycling of the units is very high due to the fact that acceptable performance during low pressure testing does not assure an acceptable level of performance at higher pressures. Potential test failures during the test at normal operating pressure would lead to a unit shutdown to less than 150 psig within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> where HPCI or RCIC repairs would be implemented. At this reduced system pressure, however, the ability to determine the root cause of the flow test failure, and identify e W ive corrective actions is severely hindered. In order to effectively determine the root cause of the test failure, as well as identify adequate corrective actions, maintenance personnel must be able to diagnose and troubleshoot the respective system's governor and controller while steam is being supplied to the system turbine at the normal operating pressure. Operational experience at Quad Cities Station following the recent (Spring 1991) refuel outage has demonstrated that the LCO time frame of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (3.2.C.4 and 3.2.E.4) is inadequate to 'dentify the root cause of the test failure and implement corrective actions. The decreased ability to identify effective corrective actions also decreases the probability that the corrective actions will result in a successful flow test when the reactor pressure is subsequently increased to accommodate further testing. If the subsequent test also failed and repairs could not be identified and implemented in the 12-hour time frame allowed by TS 4.5.C.3 and 4.5.E.3, the reactor pressure would again be reduced to less than 150 psig, thereby causing unnecessary cycling of the unit.

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Thf present requirem2nts have been found to be unduly restrictive during plant'

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startups'in not permitting continued plant _ operation when' acceptable levels of safety-are provided by the action requirements of current Specification 3.5.C.3 and 3.5.E.3. TS 3.5.C.3 and 3.5 E.3 actions are consistent with the 3 compensatory actions of:the STS. These requirements permit continued reactor operation _during the succeeding 14 days provided that for:

HPCI inoperable:

1he tutomatic pressure relief subsystem, the core spray subsystem, i the=LPCI_ mode of the RHR system and the RCIC system must remain operable until'the HPCI system is made operable.

RCIC: inoperable:

The HPCI system must remain operable until the RCIC system is made- '

operabic.

- The compensatory measures described above, combined with a reduced flow capability (as opposed to complete.unavallatility of the system), ensure.an acceptable = level of safety, given a failu k of the flow test at normal operating pressure (subsequent to passing the low-pressure flow tcst).

DESCRIEUDfL0f_IHE_NEEQJ03HANGEJHE_ CURRENLREQUIREMENISJ cont ' dl

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' The proposed. change.to TS 3.5.C.2 and 3.5.E.2 would:

1. Reduce the.Ilkelihood of unnecessary cycling of the reactor through

'the heat-up range, thereby reducing challenges to safety systems and fatigue cycling of the ieactor-vessel and components. .

2. Enhance the ability:to-determine and impicment effective corrective actions which will increase the. probability of a successful flow test when the reactor pressure is subsequently inereased to the normal operating-pressure.

3.  : Ensure that continued operation-is not permitted-unless the necessary compensatory measures are in place that will permit an: acceptable-

' level of safety,

- DEIMLED_DESCRIP_Il0K_AND_MSES_0f_IHLPR020 SEQ 3HANGES The proposed' change would:11mit-the action provision of-Specifications-3.5.C.2-and-3.5.E.2 to a failure-to adequately perform the-flow rate testing for HPCI and RCIC at low. reactor. pressure. _Any subsequent failure of the HPCI or RCIC-isubsystems at the higher pressure flow-rate test would result in application of: current-Action 3.5.C.3 (3.5.E.3). Theseiactions implement the'STS provisions which allow a 14 day allowable outage time; provided the' remaining

- high-pressure'injectio_n system and low pressure ECCS. subsystems are operable.

- The-proposed: amendment _ revision would change Specification 3.5.C.2-(3.5;E.2)-

. to read'as.follows:

"During startup following a refuel outage or an outage in which work has performed:that directly affects HPCI (RCIC) system operability, if the testing requirements of 4.5.C.3.a (4.5.E.3.a.) cannot be met, continued

reactor startup is not permitted. The HPCI (RCIC) subsystem shall be Ldeclared: inoperable, and the provisions of Snecification 3.5 C.4 (3.5.E.4) ,

shall= t,a- implemented."

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-The proposed change is- consistent with STS and. current BWR industry practice in permitting reactor startup to continue upon successful completion of the low pressure flow rate test while allowing remedial measures _to permit a 14 day allowable outage time for a single high pressure injection system, once normal; operating reactor pressure is achieved. This also requires that the remaining-high pressure injection system and_ low pressure ECCS subsystems are operable. No reliance en any action provision is made while changing the operating mode of the' Unit in the proposed amendment nor would the Unit be allowed to_ operate in any manner which has not been previously evaluated.

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ATTACHMENT 2 St# NARY Of THE PROPOSED CHANGE TO APPENDIX A TECHNICAL SPECIFICATIONS QUAD CITIES STATION UNIT I (DPR-29) & UNIT 2 (DPR-30) f UnlLLIDER-291 h

Eage 3.5/A25:5

• Change Specification reference in TS 3.5.C.2 from 4.5 C.3 to 4.5.C 3.a.

nJi EAge 3.5/4.5-7

• Change / Specification reference in TS 3.5.E.2 from 4.5.E.3 to 4.5.E.3.a.

Unit _2_(DER:30)

EA9t_3kSLs5:aa ,

• Change 1 Specification reference in TS 3.5 C.2 from 4.5.C.3 to 14.5~C.3.a.

- Eage15LL5-6 Change Specification reference in TS 3.5.E.2 from 4.5.C.3 to 4.5.C.3.a. '

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