JSP-505-93, Application for Amend to License NPF-62,chnaging Tech Spec 3/4.8.1.1, AC Sources-Operating, Including Requirement of DGs to Insp in Accordance W/Mfg Recommendations for Class of Standby Svc

Application for Amend to License NPF-62,chnaging Tech Spec 3/4.8.1.1, AC Sources-Operating, Including Requirement of DGs to Insp in Accordance W/Mfg Recommendations for Class of Standby Svc

ML20059J048
Person / Time
Site:	Clinton
Issue date:	11/04/1993
From:	Jamila Perry ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20059J052	List: JSP-505-93, Application for Amend to License NPF-62,chnaging Tech Spec 3/4.8.1.1, AC Sources-Operating, Including Requirement of DGs to Insp in Accordance W/Mfg Recommendations for Class of Standby Svc ML20059J054
References
JSP-505-93, U-602194, NUDOCS 9311100328
Download: ML20059J048 (6)

Text

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. , . Imnois Power Company Clinton Power Station ..

• P.O. Box 678

' Clinto'). fL 61727.

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, Tei 217 935-6226 Fax 217 935-4632 J. Stephen Perry . -t Senior Vice Prescent ILLIN91S-POWER U-602194 L47-93(11-04)LP }

JSP-505-93 8E.100a November 4, 1993 ,

Docket No. 50-461 10CFR50.90 -

Document Control Desk ,.

- Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Clinton Power Station Proposed Amendment of Facility Operating License No. NPF-62 (LS-93-006) 3

Dear Sir:

Pursuant to 10CFR50.90, Illinois Power (IP) hereby applies for amendment of Facility Operating License No. NPF-62, Appendix A-Technical Specifications, for Clinton Power Station (CPS). This request consists of a proposed change to Technical Specification 3/4.8.1.1, "AC Sources-i Operating," which includes the requirement to subject each of the diesel generators to an inspection in accordance with the manufacturer's recommendations for this class of standby service. IP proposes to relocate this requirement from the Technical Specifications to plant-control. led programs, consistent.

with the improved Standard Technical Specifications (NUREG-1434).

A description of the proposed change and the associated justification (including a Basis For No Significant Hazards Consideration) are provided in Attachment 2. A marked-up copy of the affected pages from the current Technical Specifications are provided in Attachment 3. In addition, an affidavit  ;

supporting the facts set forth in this letter and its attachments is provided in Attachment L 4

1P has reviewed the proposed change against the criteria of 10CFR51.22 for categorical exclusion from emironmental impact considerations. The proposed change does not involve a significant hazards consideration, or significantly increase the amounts or chenge the types of efiluents that may be released offsite, nor does it significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing,1P concludes the proposed change me.ets the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.

Sincerely yours, n -

090070 .&NL - of -

. S. Perry l Senior Vice President TAB /nis I 9311100328 931104 m O I' PDR ADOCK 05000461 - V P Pm z

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.. 'p Attachments cc: NRC Clinton Licensing Project Manager p i

NRC Resident Office, V-690 l Regional Administrator, Region III, USNRC ; .

- Illinois Department ofNuclear Safety  !

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STATE OF ILLINOIS COUNTY OF DEWITT ,

John G. Cook, being first duly sworn, deposes and says: That he is Vice President ofIllinois Power i Company; that the application for amendment of Facility Operating I,icense NPF-62 has been prepared l under his supervision and direction; that he knows the contents thereof; and that to the best of his .

knowledge and belief said application and the facts contained therein are true and correct. l l

i DATED: This day of November 1993 if i

Signed:

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i Subscribed and sworn to before me this f[N day of November 1993. 'f h

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/ Notary Public ll *0ff101AL SEN ll  ;

l Linda S. French ll Notary Public, S' ate dIEncis Ll l 1 i

ll My Commission Expires 9/U96 9: _:

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.i Attachment 2 to U-602194 Page1 of3  !

LS-93-006  ;

Raskground f i

The Clinton Power Station (CPS) Class IE AC Electrical Power Distribution System consists of the offsite power sources and the onsite standby power sources. As required by 10CFR50, Appendix A, i GDC 17, the design of the AC electrical power system provides independence and redundancy to ensure  !

an available source of power to the Engineered Safety Feature (ESF) systems.

The Illinois Power (IP) electrical system design provides a diversity of offsite sources for supplying

• power to the safety-related equipment needed to achievc ad maintain the plant in a safe shutdown  ;

condition. !, se power supplies consist of(1) the 138kV offsite transmission line which supplies the  ;

station Emgr y Reserve Auxiliary Transformer, and (2) the 345kV station switchyard ring bus which supplies the kc3erve Auxiliary Transformer. Three 345kV transmission lines connect CPS to the IP grid at the Brokaw, Rising and Latham Substations. All three lines terminate at the switchyard ring bus. [

In the event of a complete loss of offsite power, there are three diesel generator units on site that automatically provide emergency power. Diesel generator I A supplies power to Division I electrical equipment, diesel generator IB supplies power to Division 11 electrical equipment, and diesel generator IC supplies power to Division III clectrical equipment (primarily the High Pressure Core Spray l System). In supporting safe shutdown of the facility in the event of an emergency or accident, Division I is redundant to Division II.

CPS Technical Specification 3/4.8.1.1 identifies the minimum AC electrical power sources required to ,

be operable during Operational Conditions 1,2, and 3, as well as the associated actions to be taken in the event these requirements are not met. The surveillance requirements for demonstrating the- i operability of the AC electrical power sources are also prescribed. Technical Specification Surveillance Requirement 4.8.1.1.2.c.) requires that at least once per 18 months, during shutdown, each diesel generator be subjected to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service. IP proposes to relocate this i requirement from the Technical Specifications to plant controlled programs, consistent with the i improved Standard Technical Specifications (NUREG-1434) for BWR/6 plants.

DgEcriplion of Proposed Cha_nse In accordance with 10CFR50.90, IP proposes to relocate Technical Specification Surveillance  :

Requirement 4.8.1.1.2.e.1 to plant controlled programs. To ensure procedural consistency and reduce the impact of this change on CPS procedures, the remaining Surveillance Requirements of Technical i Specification 4.8.1.1.2.e are not renumbered. I 1

The proposed change is identified on the marked-up copies of the pages from the current CPS Technical j Specifications contained in Attachment 3.

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I Page 2 of 3 LS-93-006  :;

Justification for Proposed Change i

As noted above, the improved Standard Technical Specifications'(NUREG-1434) do not specifically' j include the surveillance requirement to perform an inspection of the diesel generators in accordance  !

with the manufacturer's recommendations. This inspection is a preventive maintenance activity that is  ;

assumed to occur under the plant preventive maintenance program. The improved Standard Technical j Specification for AC sources is thus based on the premise that utilities will perform manufacturer--

recommended inspections without specifically identifying them. Thus, the proposed change -is  ;

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consistent with NUREG-1434.

As IP will continue to perform the manufacturer's recommended diesel generator inspections (including the inspection currently identified in Surveillance Requirement 4.8.1.1.2.e.1), relocation of the  !

surveillance requirement from the Technical Specifications will have ' no 'effect on operability. or.- -!

reliability of the diesel generators. The diesel generators will continue to be maintained, under the CPS preventive maintenance program, in a manner which ensures system operability. All other surveillance  !

requirements demonstrating that the AC power system functions as required remain unchanged.

B_ asis For No Signifier Hazards Consideration i In accordance . ai 10CFR50.92, a proposed change to the operating license (Technical Specifications)  !

involves no significant hazards consideration if operation of the facility in accordance with the proposed l

change would not (1) involve a significant increase in the probability or consequences of any accident  ;

previously evaluated, (2) create the possibility of a new or different kind of accident from any accident  ;

previously evaluated, or (3) involve a significant reduction in a margin of safety. This request is evaluated against each of these criteria below.

I (1) The proposed change is consistent with the improved Standard Technical Specification (NUREG-1434) and does not result in any changes to the existing plant design. The diesel ,

generators will continue to be inspected in accordance with the manufacturer's recommendations  :

as part of the CPS preventive maintenance program. Since the change does not impact the. I i

ability of the diesel generators and the AC electrical power sources to perform their function,-

this change does not result in a significant increase in the consequences of any accident  ;

previously evaluated. The diesel generators will continue to function as designed and will  !

continue to be tested as previously tested. Therefore, the proposed change will not impact the- j probability of occurrence of any accident previously evaluated.  :

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. Attachment 2 ,

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Page 3 of 3 LS-93-006  ;

(2) This request does not result in any change to the plant design nor does it involve a significant change in current plant operation. The diesel generators will continue to be inspected as recommended by the manufacturer and the remaining surveillance requirements will not be  ;

changed. The change merely permits taking credit for current preventive maintenance activities s without specifically requiring the inspect, ion activity in the Technical Specifications. As a result, no new failure modes will be introduced, and the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) The proposed request does not adversely impact the reliability of the diesel generators. As  ;

stated above, the manufacturer's recommended inspections will continue to be performed. In l l addition, the diesel generators will continue to perform their design functions. This request does not involve an adverse impact on diesel generator operation or reliability. Since the diesel generator function is not affected by the proposed change, this request does not involve a significant reduction in a margin of safety.

Based upon the foregoing, IP concludes that this request does not involve a significant huards  ;

consideration.

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