RS-15-298, Supplement to License Amendment Request to Revise Technical Specification 5.5.2, Primary Coolant Sources Outside Containment.

Supplement to License Amendment Request to Revise Technical Specification 5.5.2, Primary Coolant Sources Outside Containment.

ML15320A247
Person / Time
Site:	Clinton
Issue date:	11/16/2015
From:	Simpson P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-15-298, TAC MF5291
Download: ML15320A247 (6)

Text

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4300 Winfield Road

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RS-1 5-298 10 CFR 50.90 November 16, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Supplement to License Amendment Request to Revise Technical Specification 5.5.2, "Primary Coolant Sources Outside Containment"

References:

(1) Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S.

NRC, "License Amendment Request to Revise Technical Specification 5.5.2, 'Primary Coolant Sources Outside Containment'," dated November 17, 2014 (2) Letter from Blake Purnell (U.S. NRC) to Bryan C. Hanson (Exelon Generation Company, LLC), "Clinton Power Station, Unit 1 Request for -

Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.2, 'Primary Coolant Sources Outside Containment' (TAC No. MF5291)," dated March 24, 2015 (3) Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U. S.

NRC, "Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.2, 'Primary Coolant Sources Outside Containment'," dated April 21, 2015 (4) Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U. S.

NRC, "Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.2, "Primary Coolant Sources Outside Containment," dated June 24, 2015 In Reference 1, Exelon Generation Company, LLC, (EGC) requested, in accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit,"

NRC approval of a proposed revision to the interval for performance of the integrated leak tests required by Technical Specification (TS) 5.5.2, "Primary Coolant Sources Outside Containment." Specifically, the proposed change would revise the current frequency for integrated leak testing of "at refueling cycle intervals" to "at least once per 24 months." The proposed change would also add a statement that allows the specified frequency for the

November 16, 2015 U. S. Nuclear Regulatory Commission Page 2 integrated leak testing to be met if the testing is performed within 1.25 times the interval specified in TS 5.5.2.

In Reference 2, the NRC requested that EGC provide additional information to support their review of the subject amendment request (i.e., Reference 1). The response to these requests was provided in Reference 3. In response to one of the requests in Reference 2, a revised mark-up was provided in Reference 3 indicating proposed changes to CPS TS 5.5.2.

As stated in Reference 1, starting in the spring of 2015, following the startup from refueling outage Cl Ri 5, CPS began annual operating cycles, with annual refueling outages. The Ci Ri 5 refueling outage was a traditional refueling outage consisting of both refueling activities and maintenance activities (i.e., "refueling/maintenance outages"). In May 2016, refueling outage Cl R1 will focus primarily on refueling activities with minimal maintenance activities (i.e.,

"refueling only outages") performed. With this alternating pattern between refueling only outages and refueling/maintenance outages, the interval between refueling/maintenance outages will be 24 months. EGC intends to continue performing the TS 5.5.2 leak testing on a 24 month frequency either during power operation or during the refueling/maintenance outages.

This is equivalent to performing the tests at the current refueling cycle interval (i.e., every 24 months) and will ensure this testing is consistent with other similar surveillance requirements in the Technical Specifications. This will allow CPS to maintain a minimal amount of testing during the refueling only outage and still maintain the same level of quality and safety by continuing the 24 month frequency that the primary coolant sources outside containment have historically been leak tested at during the refueling/maintenance outage. In addition, by performing these leak tests on a 24 month frequency, the availability of the safety systems tested will continue to be maintained.

As discussed in the response to a request for additional information in Reference 4, EGC intends to perform minimal maintenance activities during the refueling only outages. This means that few systems will be taken out of service during these outages. Testing during these outages will be minimized and no additional potential for increasing leakage will be introduced.

The systems have performed well over the years with little or no leakage identified. There is no basis to conclude the leakage from these systems will increase significantly during the cycle between the refueling only outages and the refueling/maintenance outages since the systems will not be operated any differently than they have in the past. The proposed change will allow EGC to continue testing the respective systems for leakage on the same frequency they are currently tested at.

However, subsequent to submittal of Reference 3, the NRC provided a follow-up question concerning the proposed mark-up of TS 5.5.2. Specifically, the NRC wanted to know if the proposed wording of the TS would allow CPS to not make repairs to equipment, components or systems worked on during the refuel only outage (i.e., the refueling outage during which leak testing would not be required) that may have resulted in primary coolant system leakage. The NRC concern is that EGC would delay repairs and any required leak testing until the next outage (refueling/maintenance outage) because the proposed TS 5.5.2 doesn't require repairs or testing until that outage. In response to this question, EGC has decided to revise the proposed TS 5.5.2 wording to address the need for leak testing following work which could result in leakage from a component or system covered by this program.

November 16, 2015 U. S. Nuclear Regulatory Commission Page 3 The proposed license amendment will continue to request that the current (i.e., 24 month) frequency for the CPS integrated leak test requirements for primary coolant sources outside containment be maintained. This will allow CPS to maintain a minimal amount of testing during the "refueling only" outage as defined in Reference 1 and still maintain the same level of quality and safety by continuing the 24 month frequency that the primary coolant sources outside containment have historically been leak tested at during the refueling/maintenance outage.

Changing TS 5.5.2 will provide the necessary flexibility to perform the testing based on a calendar month basis rather than on cycle length.

CPS TS 5.5.2, "Primary Coolant Sources Outside Containment," currently states:

"The program shall include the following:

a. Preventive maintenance and periodic visual inspection requirements; and

b. Integrated leak test requirements for each system at refueling cycle intervals or less."

The newly revised TS 5.5.2, would state:

"The program shall include the following:

a. Preventive maintenance and periodic visual inspection requirements;

b. Integrated leak test requirements for each system at least once per 24 months; and

c. In the event work is performed which could result in leakage from a component or system covered by this program, a visual inspection shall be performed and repairs made as required.

The specified frequency for integrated leak testing is met if the testing is performed within 1.25 times the interval specified."

The revised TS 5.5.2 mark-up is provided in the Attachment to this letter.

EGC has reviewed the information supporting a finding of no significant hazards consideration that was previously provided to the NRC in Attachment 1 of Reference 3. The proposed revision to TS 5.5.2 provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments contained with this letter. If you should have any questions concerning this letter, please contact Mr. Timothy A. Byam at (630) 657-2818.

November 16, 2015 U. S. Nuclear Regulatory Commission Page 4 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 16th day of November 2015.

pectfully Patrick R. Simpson Manager Licensing Exelon Generation Company, LLC

Attachment:

Revised Mark-up of CPS Technical Specifications Page cc: NRC Regional Administrator, Region Ill NRC Senior Resident Inspector Clinton Power Station Illinois Emergency Management Agency Division of Nuclear Safety

TTACHMENT Revised Mark-up of CPS Technical Specifications Page

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.1 Offsite Dose Calculation Manual (ODCM) (continued)

C. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of, or concurrent with, the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made.

Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

5.5.2 Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The systems include the:

a. LPCS System;

b. HPCS System; C. RHR System;

d. RCIC System;

e. Suppression Pool Makeup System;

f. Combustible Gas Control System;

g. Containment Monitoring System; and

h. Post-accident Sampling System (until such time as a modification eliminates the PASS penetration as a potential leakage path).

The program shall include the following:

a. Preventive maintenance and periodic visual inspection requirements; ad

b. Integrated leak test requirements for each system at refucling cycle intervals or le least once per 24 months--;

and C. In the event work is performed which could result in leakage from a component or system covered by this program, a visual inspection shall be performed and repairs made as required.

The specified frequency for integrated leak testing is met if the testing is performed within 1.25 times the interval specified.

(continued)

CLINTON 5.0-8 Amendment No. 45