JSP-072-93, Application for Amend to License NPF-62,changing TS 3/4.6.1.2 Re Primary Containment Leakage to Reflect NRC Approval of Proposed Partial Exemptions from 10CFR50,App J Re Containment Integrated Leakage Rate Testing

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Application for Amend to License NPF-62,changing TS 3/4.6.1.2 Re Primary Containment Leakage to Reflect NRC Approval of Proposed Partial Exemptions from 10CFR50,App J Re Containment Integrated Leakage Rate Testing
ML20128M743
Person / Time
Site: Clinton Constellation icon.png
Issue date: 02/17/1993
From: Jamila Perry
ILLINOIS POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20128M747 List:
References
JSP-072-93, JSP-72-93, U-602097, NUDOCS 9302220260
Download: ML20128M743 (13)
v • d • e


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JSP-072-93 February 17,.1993 10CFR50.12 10CFR50.90 Docket No. 50 461 Docurnent Control Desk Nuclear Regulatory Conunission Washington, D.C. 20:55

Subject:

Clinton Power Station Proposed Amendment of Facility

  • Operatine License No, NPF 62

Dear Sir:

Pursuant to 10CFR$0.12 and 10CFR50.90, Illinois Pow - Company (IP) hereby applies for partial exemptions from the requiremes.cs of 10CFR50 Apeendix J and an associated atnendment of Facility Operating License No.

NPF-62 and Appendix A Technical Specifications for Clinton Power Station (CPS). This request consists of three proposed partial exemptions from tbs requirements of 10CFR50 Appendix J regarding i

contairunent integrated leakage rate testing, three proposed changes to associated CPS Technical Spenification 3/4.6.1.2, " Primary Containment Leakage," and changes to the CPS Technical Specification Bases and Operating Licenso NPF-62 to reflect NRC approval of the proposed partial exemptions.

For each of the proposed partial exemptions noted above, a description of the requested exemption, the associated justification, and a description of thu special circumstancen (as required by 10CFR50.12) are provided in Attachment 2. In addition Attachment 2 provides a deucription and the associated justification (including a Basis for No Significant flazards Consideration) for each of the proposed operating license and Technical Specification changes noted above. Marked up copies of pages from the current operating license, Technical

!_ Specifications and Bases for CPS are provided in Attachment 3. . Further, L

-1gQ{@@affidavitsupportingthefectssetforthinthisletterandits.

l attachments is provided in Attachment 1.

_ _ IP has reviewed the proposed changes against the criteria of 10CFR51,22 for categorical exclusion from envirotunental impact considerations. The proposed changes do not involve a significant n e I L -9302220260 930217 \  :

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i hazards consideration, or significantly increase the amounts or change the types of of fluents that may be released offsite, nor do they significantly incre.ssa individual or cumulative occupational radiation -

exposures. Based on the foregoing, IP concludes the proposed changes meet the criteria given-in 10CFR$1.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statemtnt.- l Please note that IP desires to implernent this request during the fourth refueling outage at CPS (which la currently scheduled to begin  !

September-26, 1993). Therefore, IP requests that this appilcation be -i reviewed on a schedule sufficient to support this outage. l Sincerely yours,

. S.* '

J\S.Perr M nior Vice President I

DAS/msh Attachments J

cc: URC Clinton Licensing' Project Manager NRC Resident-Office, V-690 Regional Administrator, Region III USNRC Illinois Department of Nuclear Safety 5

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Attachraent 1 to U.602097 l

STATE OF ILLINDIS COUNTY OF DEWITT  !

J. Stephen Perry, being first duly sworn, deposes and says:. .That.hu is Senior Vice President of Illinois Power Coinpany; that the application for amendment of Facility Operating License NPF462 has been prepared under his supervision and direction: that he knows the contents thereof; and that to the best of his kcowledge and belief said application and the facts contained therein are t rue and correct.

DATE: Thiu #7_ day of February, 1993.

S i r,ned : _

i Ste h h A%g dien Perry Q Subscribed and sworn to before rne this / day of February, 1993.

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Attachment 2 l to U 602097 I LS 91 016 page 1 of 10 l t

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n order to ensure offsite doses remain below those previously evaluated in <

the event of a dcaign basis accident, leakage from the primary contairunent t

toust be limited. To ensure that contaitunent leakage remains within theso  ;

limits, periodic leakage rate tents are performed. Specifically,  ;

10CTR50.54(o) requiren primary reactor contairments for water cooled power reactors to be subject to the leakage rate testing eequirements not forth in Appendix J to 10CFR50. Clinton Power Station (CPS) Technical Specification l (TS) 3/4.6,1,2, " Primary Contairunent Leakage," provides additional requirements for performing leakar,e rate testing and specifies the associated t l irai ts . The leakage rate testing program for CPS is described in Section 6.2.6 of the CPS Updated Safety Analysis Report (USAR).

As described in detail below, IP is proposing to revise TS 3/4.6.1.2_to make several changes to the associated Icakage rate testing requirements. ~1h e l proposed changes siso necessitato that IP request partial exemptions from

10CFR50 Appendix J in accordance with 10CFR50.12.

E.C3eriotion o[,,,,2unsjad ,CJLnj)gna l -

In accordance with 10CFR50.12, Illinois Power (IP) is requesting the following 3 partial exemptions from 10CFR50 Appendix J
'

(1) A partial exemption from the 10CIM50, Appendix J, Section l

III.A.1.(a) requircuent to sten a Type A test ( con talrunent integrated leakage rate test (C11J1T)) if excess lve leakage is detected.

(2) A partial exemption from the 10CFR50, Appendix J Section 117.D.1.(a) requirement to perform the third Type A test'of-each  ;

10 year scrvice period when'the plant is shut down for the 10 year  :

plant inservia.e inspections. 't (3) A partial exemption from the 10CFR50, Appendix J, Section III.A.S.(b) acceptance criteria for Type A tests with respect tn determining the frequency of subsequent Type A tests.

Consistent with the proposed partial exemptions from 10CFR50 Appendix J, I? Is  !

requesting changes to paragraph 2.D of the operating license for- CPS (NPF 61) '

to reflect approval of these partial exemptions. These changen are being

+. proposed in accordance with 10CFR50.90 and are reflected in Attachment 3.

F IP also requests the following changes to CPS TS 3/4.6.1.2, "Primar-/

Contaitunent Leakage. " These changes-are being proposed in accerdance with 10CFR50.90 and are reficcted in Attachment.3 (1) An editorial change to TS 3.6.1.2 Limiting Condition for. operation (LCO) item "a" to correct its format.

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to U-602097 LS 016 Page 2 of 10 (2) A change to Surveillance Requirement 4.6.1.2.a to delete the requirement to perform the third Type A test of each 10 year service period during the shutdown for the 10-year plant inservice insyctions. This is consistent with proposed partiai exemption (2) above.

(3) A change te Surveillance P.equirement 4.6.1.2.b to require the "au.

found" Type A test results to be less than or cqual to the inaximum allowable leakage rate (La). This proposed change would also require the "aa-1cft" overall integrat3d containment leakage rate to be less than 75 percent of La prior to plant startup. These proposed changes are consistent with proposed partial exemption (3) above.

IP is also providing the attached changes to the CPS TS Basec to provide clarification regarding *as.found" and "as-left" leakage rates and to reflect NRC approval of the proposed partial exempt _lons to 10CFR50 Appendix J. These Bases changes are also reflected in Attachment 3.

Just Hig/gjsn for Proitosed Chane_es As described above, the nroposed changes consist of three partial exemptinns from 10CFR50 Appendix J, three prorosed changes to TS 3/4.6.1.2, and changes to the CPS TS Danes, and the operat;ng license to ref1cet approval of the partia' e x mrp t uns . Each of these proposed changes are discussed separately holow.

Eartial icxemptions from 10C FR 50 lune _inij.ni, 10RRSO Append 5 J_jfe_g_t f i n llLA_L,1gl Sec tion III . A. l . (a) of 10CFR50 Appeadix J requires that a Type A test be terininated if, during the test, potentially excessive leakage paths are identified which would either interfere with satisfactory mmpletion of the test or which would result in the Type A test not meeting the applicable acceptance criteria. The periodic Type A tests performed at CPS are conducted at the calculated peak containment internal pressure of 9.1 psig (Pa), and the applicable acceptance critrrion is contained in Section III.A.S.(b)(2) of Appeadix J. This criterion states that the measured leakage rate (Lat ) at Pa shall ba lets than 75 percent of the mi.ximum allowable leakage rate ( La) . (These various terms are defined in Section II of Appendix J.)

Section III.A.1.(a) further requires that, after terminating a Type A test due to potentially excessive 12akage, the leakage through the potentially excessive leakage paths be measured uning local leakage rate testing (llRT) methods and repairs and/or adjustments to the affected equipment be made. A Type A test shall then be conducted (i.e.,

reconducted).

. IP proposes that, when excessive levkage is found during a Type A test, the test not be terminated. Insterd, the significant laaks will be identified and isolated and the Type A test continued. After completion l

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Attachment 2 to U 602097 LS91-016 Pc.ge 3 of 10 of the modified Type A test (i.e , a Type A test with the significant leakage paths isolateJ). local leakage rates of those paths isniated dur%g the test will be rtensured before and af tr r necessary repairs and/or adjustuents are reade to those paths.

Pursuant to the above change, IP proposes that an "as-found" Icakagi i

rate for the Type A tes,t he determined by adding the "minimurn pathway

  • local leak.nge :ates measured before any repairs and/or adjustments are made to the leakage paths isolated during, the test, to the containment integrated leakage rate measured in the modified Type A test. This adjusted "as found" leakage rate is to be used in determining the success or failure of the test and hence the scheduling of subsequent Type A tests in accordance with Section III.A.6 of Appendix J.

Finally, and as part of the above change, IP propones that the -

acceptability of the overall containment integrated leakage rate be determined by calculating an "as left" containment overall integrated Icakage rate and cornparing this to the acceptance criterion of Section 111. A. S. (b)(2) of 10CFR50 Appendix J (which requires Lam to be less than 75 percent of La). The "as-left" containment overall integrated leakage rate is determined by adaing the "minirtura pathway" local leakage ratou rneasured af ter any repairs and/or adjustinentu are made to the leakage paths isolated during the test, to the cont aintnent f.ntegrated leakage rate measured in the modified Type A tent.

The only dif ferences between this proposal and the requirements in Section 111.A.1.(a) of Appendix J are that: (1) the potuntially excessive leakap;e paths will be repaired and/or ad. justed af ter completion of the Type A rest rather than before the test; and (2) the Type A test leakage rate is partially determined by calculation rather

, thaa by direct measurement. With respect to this latter issue, the limiting value of the overall containment integrated leakage rate in TS 3.6.1.2 LCO item "a" is 0.65 percent by weight of the containment air 9

over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period nensured at an internal containnent pressure of 9.0 psig. The measured "as left" Iccal leakage ates through the paths isolated during the modified Type A test will normally be a small fraction of th!s limit. As a result, the values of thcae "as left" local leakage rates will normally represent a relatively small correction to the overall containment integrated leakage rate determined by the modified Type A test. Accordingly, there will be very 11ttle difference between a calculated "as left" prinary containment leakage rate (i.e., a modified Type A test) and one which would be directly measured in strict compliance with the requirements of Section III.A.1.(a). With respect to the issue of inaking repairs and/or adjustments to potee.ially excessive leakage paths during a Type A test rather than after aborting (but before repeating) the test, there i s no significant difference in the end result since "as left" local leakage rates will be raquired to be within an acceptable lirait.

The above proposed partial excomtion does not pose any undue rick to pubite health and safetf in that IP will continue to derunstrate that the overall containnent integrated leakage rate is less than the value current 1j specified in the CPS TS prior to plant restart, thus ensuring continued leakage integrity of the containment in neardance with the

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'to U 602097 LS91-016 i Page 4 of 10 l intent o.f 10CFR50 Appendix J. Accordingly, the proposed rnodified Type A test procedure achieves the unoerlying purpose.of.the rule, thereby-demonstrating that one of the special circunstances described in 10CFR50.12(a)(2)(ii) applies. In addition, this exempcion is signilar to -i a request which has previously been approved for Carolina Power and l Light Company's 11. B. Robinson plant and a requent previously approved l for Union Electric's Callaway plant, j i

This exemption request requires no corresponding proposed change to the- l CPS TS (other than the acknowledgement of the exemption in the CPS l

operating' license and CPS TS Bases). .

100FR50 Annetidix J SectJ.RD._Ul.2d LAl Section III.0.1.(a) of 10CFR50 Appendix J requires, in part, " ...a set of three Type A tests shall be performnd_at apprcxirantely equal intervals during each 10 year service period; The third test of each .,

set shall be conducted when the plant is shut down for the 10-year plant __  ;

inservice inspection." IP proposes to perform the three Type A tests at approxtraately equal intervals within each 10-year period, with the third test of each set conducted as close as practical to the end of the 10-year period. However, there would be no required connection between.the Appendix J 10 year interval and the insorvice inspection 10 year  ;

intorval. ,

The 10-year plant inservice inspection (ISI) is the series of 1 inspections performed overy 10 years in accordance with Section XI of '

the ASME Boiler and Pressure Vessel Code and Addenda as required by-10CFR50.55a. IP performs the ISI volumetric, surface and visual '

  • exarninations _ of cor .,nents and system pressure tet ts in accordanen with 10CFR50.55a(g)(4) chroughout the 10-year inspection interval. The raajor "

portion of this effort is presently being'perfortned every 18 months during the refueling outages. As_a resuiti there is no extended outage in which the 10 year ISI examinations are performed.

Each of these two surveillance tests (i.e.. .the Type A tests.and the 10+

year JS1 program) is independeqt of the other and provides assurances of different plant characteristics. The Type A test assures the required.

lenk-tightness to demonstrato compliance with the guidelines 'of 10CFR .

Parr. 100 Tho 10 year ISI prograre provides assurt.nce of the integrity of the structures, systems, and cornponents as well as verifying operational readiness of purnps.and valves in complianco with -

10CFR$0.55a. There is no benefit to be p t.ned by coupling these requirernents to the same refualing outage in that elernents of the CPS '

ISI program are conducted throughout each 10 year cycle rathee than during a refueling outage at the enu of the-.10 year cycl.c.

Consequently, the subject coupling requiretner.t offers no benefit- either to safety or to economical. operation of.the facility. Accordingly, the- .[

subject exemption request rauets the underlying-purpose of the rule- ~

{10CFR50.12(a)(2)(ii)).

Consistent with this exemption request, a proposed change to CPS TS' Surveillance Requirement 4.6.1.2.a is also being requested, as described later in this submittal.

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A.ttachment 2 to U 602097 LS+91 016 Page 5 of 10 10CFR$8 Appr. wild Section ULA,Mb_1 Section III A.5. (b)(2) of - 10CFR50 Appendix J establishes an acceptance criterion for the total contaitunant integrated leakage ate (Lam) measured at the peak containment internal r reasure (Pa) calculated for the design basis cceident. Since the per.5cdic Type A teats at CPS are conducted at Pa, the acceptance criterion for these tests is that. Lam bc

,- less than 75 percent of the maximum allowablu leakage rate La. This t valu: is 0.65 percent by weight of the containment air. per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, as spectiied in TS 1.6.1.2.a.

Consistett with the previously described request rege.rding Section III . A.1. (a) of 10CFR50 Appendix J , IP proposes to establish two conditions for determining the acceptability of the periodic Typo A -

1- tests. These two conditians are the "as-found" leakage rate and the "as le f t" Icakage rso. The "as-found" leakage rate is calculated by-adding the of f ferencea tetween the "as f ound" and "as lef t" messured local leakage rates for each Type B and Type C test performed prior to q

, the Typo A tent to the leakage rate measured during the Type A test. .

[Ilowever, these Type B and C tests may be performed af ter the-Type A test in those cases when venting of the associated system is not required per Section III . A.I . (d) of 10CFR50 Appendix J. ] In additit 3 lu the event that potectially excessive leatage paths are identified which would interfere with the satisfactory complation of the periodic Type A test, such paths will be isolated dueing the test (as' described previously), the Type B er Type C "as-found" leakage rate for the isolated penetrations will be measured af ter completion of the lyp A test and added to the Icakage nensured during the modified Type A cst.

The "as 1s rt" leakage rate is calculated by adding the local leakage rates mens .cd after any required. repairs and/or adjustments are made to those leakarp paths isolated during the test, to'the containment Integrat ed Ica'uge rate measured in the modified Type A test. .A

! 1hc spec ric proposal for the revised accep ance criterio in 1ieu of the present single criterion in 10CFR50 Appendh J Section III . A.S. (b)(2)

(f.e_, Lam less than 0.75 La) is that tne "as-found" allowable leakage rate must be within La and the "au- wit" allowahls leakage :: ate must ha less than 0.75 La.

The basis for this proposal is that the acceptance criterion for Lam was astablished in Appendix J as 0.75 La in order to provide a margin of 25 percent (i.e., 0.25 La) to cecount f or possible deterioration of the-reactor primny containmene Icak cl6htness during the time herween the periodic Typo A tasta. The value of La is the tctual leakage rate assumed in the accident analyses in Chapter II of the USAR. (Re fer - to Table 15.6.5-5 of the CPS USAI.) There is no need far the 25 pe cent margin to account for *leterioration at the end of a Type A test interval since the "as- found" le?kage corresponds to the actuni condition of t.h"

.cntainment at the end of the rest interval.

The proposal for the accepunce criterion for the "as-found" maximum allowable leakage rata of Le is acceptable on the bacia that, throughout the prior type A test interval, the reactcr primary containment leakage w uld have been at or below the value currently required in the CPS TS I

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Attachment 2-to U 602097 LS91-016 Page 6 of 10 and within the value assumeu in the accident analyses in the-CPS USAR.

Furthermore. the proposa\ continues to naintain the requirement that the reactor primary containment (i.e., the "as-left" condition) leaxaSe rate be re-established to less than 0.75 la prior to restart of the plent.

There is rided assurance that there will-not be any significant undetected degradation in the reactor primary containment leakage during each Type A test interval in that the primary contributors to potentially excessive leakago paths will be measured during the required periodic Typo B and Type C tests. These latter tests will be cenducted at iatervals no greater than 2 years. (See 3ections III.D.2 and vll.D,3 of Appendix J and Sut eeillance P aquit ament 4.6. .2.d.) The principal contributors to any deterioration in the containment 12 akag.) rate would thareby be detected and cor*ceted at least onen between performances of -

Type A tests.

The proposed exemption request does not pose any undue risk to public "3

healrh and safety in that IP will continue to demonstrate the containment overall integrated leak ra: e will be less than the value currently specified in the CPS TS and 10CFR50 Appendix 3 prior to restart after a refueling outats using the prnsent acceptance criterion

'f 0. 75 La Further, any potentially excessive leakage paths wil3 continue to be rapaired and/or adjusted prior to restart and at 3 intervals no greater than 2 years, there.by etntinuing to cusure the -

integrity of the containuent in accordance witi the intent coscribed in 10CFR50 Appendix J. Based un ebese considerations, the proposed alternativa acceptanco criteria for thn leak-ti-htness of the reactor primary containment will continue to ensure its integrity with respec:

to compliance with the maximum permissible containment leakage rate specified in the CPS USAR. Accordingl f, the proposed modified Type A test acceptance criteria achieves the underlyiag purpose cf the rule,

  • thereby demonstrating that one of the special circumstances described in 10CFR50.12(a)(2)(li) applies.

Consistent with this e::emption request , a proposed change to CPS TS 4.6.1.2.b ic also requested, an deser tbed below.

fronened Changes To TS 3/4.6.1.2 The proportC changes to CPS TS 3/4.6.1.2 consist of an editorial change to LCO item "a", a change to Surveillance Requitement 4.6.1.2.a to delete the requirement to perform the third Type A test of e sch 10-year se :vice perio 1 during the shutdown for the 10-year plant inservice inspection, and a change to Surveillance Requirement 4.6.1.2.b to require the "as-tound" Type A test results to be within La and require the "Is-left" overall integrated containnsnt leakage rate to be less than ).75 La prior to plant startup. Euch of chese changes is discussed separately ielow.

IS 3.6.1.2 Item "a" This change is coitorial. The LCO item is currently formatted to allow subitens. However only one subitem is included. As a result, the

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Page 7:of 40l current format can create confusion. This ebenge roerely deletes?theV colon and "1.". ,Therefore,-t$ere is no change to.the~te'chnica1L requirernents of 6.his LCO item.

M 4.6.1'.2.a The proposed changes to this surveillanei requiremenyare providedL :o he; consistent with the partial exemption frem 10CFR50 N pendix JcSection IIT. 9.1.(a) described previously. As already'noted,-there-islno benefit-in coupling the requirements of the 10 year ISI program with those for performing Type A leaiage rate tests.. Each of-thuse two surveillances (i.e., the Type A tests and the 10-year ISI. program)-is independent of i the other and providas assurancea of different plant ~ characteristics; h Type A tests assure the required leak-tightness for the reactor:

primary costainment to demonstrate compliance eith the guidelines;of' 10CFR Part 100. Tne 10 year !31 program provides assurance of integrity: -

of the plant's str tetures, systects , ard components as well 'as verifying operational readiness of pumps and valves in cornpliance with 10CFR50.55a. *he re it. no safety-related concern necassitating the.ir coupling to the same reiueling outage. As a result, IP is proposing 1to delete this unnecesser.ily restrictive requirement from this sur re111ance  ;

requirement.

TS 4 6.1.2-h .

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, The proposed changes to this survoillance requireiuent are provided to be j consistent with the requested partial exempr. ion froto 10CFR50 Appendix J Section III.A.S.(h) discussed previously. Accordingly, IP proposes that this surveillance requirement for the Type A tests _ be clarified 'and;.made

.nore specific by establishing an "as found". condition and an'*as-left"-

r condition, each with its own acceptance criteria. IP.is proposing to ut!112e two acceptance criteria in lieu of the present singleEcriterion of 10CFR50 Appendix J Section III . A.S. (b) cited above L(i.'e ; ,- 1.am lussi 1 j i

chan 0.75 La1 The two criteria proposed are that tLe "as-found" allowable leakage- rate must be within La and the ."as left" allowable ' .i leakage rate must be lous than 0. 75 La.

1 IP proposes that't.9 "as-fovnd" Type A test.. result hhLthe leakagofrate. _

calculated by adding the differences between the "as-found" and "as-left" reeasured local leakage rates from each Type B and Type C test) performed prior to thitype A test to the~ 1eakage rate raeasured during.

the Type A test. Those Type B and Type C taats are usually conducted prior to conducting the Type'A test. -[Howaver, these. Type B and C-tests may be performed af ter -the Tyie .A test in- those m.ses when ventin$ of

.the associated syster is not required per Sec':lon:111. A.1. ( 4) < of 10CFR50:

Appendix J.) In addition, in the event that potentially excessive:

leakage paths are identified which would interfere with the satisfactory -

completion of the periodic Type A1 test, such patns vould be isolated 1(.as discussed previously), the Type B or- Type:C "as4 found* leakage rates t

would be determined for the 'isolaced penetrations after completionfof the Type A test and added to the:overall integrated leakage rate:

measured during the modified' Type A test. The "as-left" condition is; calculated b3 adding the local leakage rates measured after- any! required l u

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LS+91'0163 Pagel8lof_10 _

repairs __and /or adjustments are made to: those leakage paths- isolated during the' test. to the containment integrate leakage rate measured in, the modified Type _A' test.

The_ acceptan:e criterion for lam ~ was established in Appendix' J as 0.75 La'in order to prqvide a margin of 23 percent (1 e., 0.25-La);to account _ q for possible dcterioration of the reactor- primary 7 containment leak l O

tightnoss during the time between periodic Type- Af tests, The1value ofi La-is the leakage rate assumed'in the' accident ana$yses in Chapter-15tofs

, the-USAR. (Refor to Table 15.6.5-5 of the CPS USAR )- -There 16 n6 need for f.he 25 percent margin et account for deterioracion at the end of a Type A test interval s f ace the _"as-found" leakage corresponds;to the:

actual condition of the containment at_the end of!the test interval.

Thets is added assurcnce that there_will not-be any significanc-undetected degradation in the reactor primary containment leakage during~

each Type A test ieterval in that;the' primary contcibutors to.

, potentially excessive leakage pat'.is will be measured curing the required periodic Type B and' Type C tests. These_latter tests vill'be conductedE at intervals no Breater than 2 yearn . (Refer to Section III;D.2 and III .D. 3' of Appendix J and Surveillance Requirement 4.6.1,2.d.) . The principal contributors to any deturioration in the-containment leakage

, rate would.thereby.be detected and corrected.at least once:between_ Type A tests. The air locks will also continue to_be tested at intervals of' 6 aanthe.

On=the above basis, the acceptance criteria for. determining the-frequency of the next Type A test should be based on the ."as-fotma" Type A test results. Ensuring that the "as-foun~d" leakage is less . than La -

verifies that the containment hes performed acceptably since the last -

Type A' test and that the current _ surveillance frequency is adequate. .In addition,-a requirement has been added to ensure that theLrequtred10.25 Ta margin to account for degradation has been restored prior. to plant restart, 7:

Channes lo the CPS TS Hasn I

W Proposed changes to the CPS Bases have alto'ocen' included in Attachment 31 The changes would reflect that CPS has_ oeen granted the< partial txemptions-p f om 10CFR50 Appandix J proposed above. To addition,Jthe'changen would identify .how "as- found" and "as-lef t" overall integrated-leakage. ratas are determined, these prnposed changes are-consistent withLthe proposed partial *

? exemptions and the proposed changes tn TS'3/4.6.1.2 described'above, f,hannen to the Opeymine LicAnsa In addition to changes to the Bases for TS 3/4.6.L 2, U fis requesting changes to Operating-License NPF 62 parsgraph 2.D to' reflect NRC approvallof the

, partial exempt-lons to 10CM15P Appendix J. proposed- above. _ These changes:merely h document NRC approval. of * ^> r i oposed exemptions and ident ify the ' location ;

[ vbrre-the-special:circumst- regarding thest.exemptionr are_ identified.

' Dais change.does not result in any technical changes.to
plant operatioh-requirements - other than 'those previously discussed above ,

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'LS-91 0163 Page.9 6fL1_Of d

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4 ~;1 a -Basis 1for No'Sientftcant Hazarch_ Consideratig In accote rce with 10CFR50.92, a proposed changeJto the Operating' License

'(Technical Spevifications)-involves-no r.ignificant hczards>-considerations (if operation of the facility in accordance with the: proposed change would not:

(1) involve la significant increase in'the probability lor consequencesnof:any- ,

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ace! dent previously evaluated, or (2) create the possibility.of a new(orf '  ;

different kind cf accident.from iny accident' previously-evaluated, or (37

% involve a significant reduction .in a margin of csafety; LThe proposed chan668 "

are evaluated against ca.h of these criteria below. ' ,

(1) Those proposed operating licer.se and TS changes constat offeditorial;andi technical changes, The editorial changes merely deflect approvalof, d partial xemptiens from 10CFR50 Appendix J and make an editorial format _

change. The- technical changes insolve dele:Lon e i the requiremer.tJto-

  • perform the third Type A test for each 10 year service period during the; shutdown for the 10-year-plant inservine inspections and a change to base the frequency;of subseque nt Type A testa on an _"ask found" leakag~e: --

limir of La and require the "as-left" overall containment . integrated-.,  ;

leakage rate to be less then 0.75 La prior to plant restartc These two-

, technic I changes only involve containment leak rate testing .

< q requirements' and are based on partial exemptions from Appendix J to-10CFR50s Becauno these changes only. involve : Leak rate testing, ;they

  • cannot increase thJ probability of any accident previously evaluatedJ '

I With respect to elimination of the requirement to' perfonnl the third. Type

, . A test f<:r each 10 year service period.during the' shutdown for the 10- ,

year pinnt inservice inspections, there is no significant benefitLiu_

coupling these two surve 91ances. Each of these two surveillances-

' ~

(i . e._, - the Type A testn and the 10-year -ISI program)- is independent of-l' the other and providea asst rances of d.ifferent plant-.- characteristics.

The Type A tests assure the' required leak-tightness for the reactor- 4 primary containment to demonstrate'enapliance with the.guidelinsa.of-10CFR Part 140. Tha 10iear ISI program provides assurance of-the?

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integrity of the plant 9 structures,. systems, and components as,woll as .

1 verifying operational readiness of pumps and valvas in compliance . withe ,

10CFR50.55a. There is no safety-related concern necessitatitjg .their' y coopling to the same refueling outage. As a "esulti this chanSe cannot;

~

i increase the consequences- (i.e. , ~offsite dose) of any accident q previously evaluated.

L 5 3 With respect to the change to the basis for determining the frequency?

for perforalng subsequent Type:A tests, this-change does:not_ increase- -

the consequences of any accident previous 1y evaluated. The acceptance-cri terion.for Lam Vas established in Appendix -J as 0 75 -La in order . tu provide a margin of 125 percent - (i .e. ,- 0. 25 La) - to . account - for possiblei '

y deterioration of _ the reaccor primary containmhnt leak-tightness betwoon ' w n e the; periodic Type A L eosts. Thel yalue of La is' the leakage rata _; assume'd-  ;

in the accident analyses in Chapter 15 of the USAR. /,Referito Table 15.6.5-5 of the CPS USAR.)--Per these; analyses, offsite doses resulting j

, , from_a design-nasia loss-of coolant accident were calculated to be 4,4 .

Rem whole body and 163 Pam inhelation at_ the ' Faclusion Area bcmndaryland. ,

1.7 Rem whole_ body ond 156 Rem Inhalation at the-Low Population Jone p ,

boundary. (Refer to Tablu 15.6.5 6 of the ' CPS USAR.) - These calculated - _

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doses are well below the --10CFR100,11 guidelines of l25 Rem 'whoicibody and 3

. 300 Rem total. InLaddition,i here t 'is no need for ths 25-percent' margin to'acconnelfor deterioration.atLthe end of a TypeLALtest interval sincei 0 the~"as founda 1eakage correspoc.ds to'thofactual condition'of the L

containment 'at the end of--tha test. interval. = - Moreovern with= respect: to "as-left" leakage, the 0.75 Lalacceptanca' criterion of 10CFR50: Appendix ~

J wil11 continue to be required;to: be~ metTprior _to -plantf restart; i There is also added assurance that there_ will not be any :signtff cancf undetected degradation in tne reactor primary containment leakage during; each Type A test interval;in .that the: primary. contributors to -

potentially excessive leakage paths will be measured during theLrequired.

~

periodic Type b and Type.C tests. Thesa latter tests will be conducted at intervals no greater than 2 years. (Refer to--Section III.Di2 and: N III,D.3 of: Appendix J and Surveillance Requirement 4.6.li2.b))f ? The

-principal contributors to any deterioration in the containment? leak gen rate would ;hereby be detected and; corrected at lobst once between ;TypeE -

, A tests. The air locks will also centinue to' be -tested /st Jntervals ofE 6 months.

Therefore,-ba od on the-above, these; proposed changes;v141_not'incenasen the probabili ty or the consequences of 'any_ accident previously evalnated.

1 (2) These proposed. changes do nor involve any. change to the plant /designior operation, As discussed above,.thesu changes cannot increase;the-

, consequences of any accident previously evaluated; As a' result,Jno!new5 failure modes are created. Therefore, these proposed changes'cannot'-

create the possibilj tyL of any new-or different kled: of: accident. from = any:

accident previously evaluatedt (0)' As previously noted. ; the proposed changes - consist _ of. editorial andL .;

, technical ch'nges.

a The editorial changen doinot directlyfiruolve or  :

impact any margin of safety as they merely acknowledge approvalmof -

propoced-partial examptions . from 10CFR50 Appendix J and makefan-editorial format change. The proposed 1 technical changes,(to delete'the

' requirement to perform the third Type A test forfeach 10 year service ~

period during.the shutdown.for the 10-year plant inservice inspections; - N to base the frequency _ of subsequent Type A tests on an "as-found" -

leakage limit of La and require the "as left" overall-containment:

integrated-leakago rate to be leas'than 0.751La prior,to> plant restart) do not-change. the ' acceptance. criteria that must be met for~ 1nservica inspections; do notL relax the "as-lef t" condicion-of the containment that 'must bo met prior to plant restart :and do not change the' requirements that must be met between plant refueling;outagna.

Therefore. ;these proposed changes do not result in afsigniticant?

veduction in, the -margin of safety.

Based upon the_t~oregoing,-_ Illinois Power has concluded-that thesefproposed changes do not' involve a significant hazards consideration.

9 4

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