ML20116N049

Submits Rev to 960419 Application for Amend to License NPF-62 Re Proposed Relaxation of TS Requirements for Moving Control Rods in Mode 5 (Refueling),Per Discussion W/Nrc. Replacement Pages for TS Encl

ML20116N049
Person / Time
Site:	Clinton
Issue date:	08/15/1996
From:	Connell W ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20116N057	List: ML20116N049 U-602623, Proposed Tech Specs 3.10.10, Single Control Rod Withdrawal- Refueling
References
L47-96(08-15)LP, L47-96(8-15)LP, U-602623, WC-260-96, NUDOCS 9608210235
Download: ML20116N049 (4)

Text

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i. 1 j . lilinois Power Company i

Chnton Power Station

, P.O. Box 678 l Clinton.ll 61727 '

Tel 217 935-5623 j '- Fax 217 935-4632

]I Wilfred Connell Vice President ILLIN915 u-6026u l,

P6MR uv-*( 08-15 >te 8E.100c

WC-260-96 l August 15, 1996 l Docket No. 50-461 10CFR50.90 Document Control Desk

Nuclear Regulatory Commission Washington, D.C. 20555 1

Subject:

Revision to Clinton Power Station Proposed Amendment of l Facility Operatina License No. NPF-62 (LS-96-002) l

Dear Madam or Sir:

By letter dated April 19,1996 (letter number U-602569), Illinois Power (IP) submitted an application for amendment of the Clinton Power Station (CPS) Operating License (License No. NPF-62) to incorporate proposed changes to the CPS Technical Specifications (Appendix A). IP's request proposed relaxation of a number of the TS requirements that are currently applicable when moving control rods in MODE 5 (refueling). Although IP's request was technically sound, discussions with the NRC staff reviewer identified a preference for an alternate format or means ofimplementing the proposed changes within the Technical Specification based on IP's April 19,1996 amendment request.

Accordingly, Attachment 2 to this letter provides replacement pages for the proposed changes to the CPS TS contained in Attachment 3 to IP's April 19,1996 amendment request. Attachment 3 to this letter provides replacement pages for the proposed changes to the CPS TS Bases contained in Attachment 4 to IP's April 19,1996 amendment request. It should thus be clear that Attachments 2 and 3 of this letter supersede, in their entirety, Attachments 3 and 4 ofIP's April 19,1996 amendment reques . Following NRC approval of this request, IP will revise the TS Bases in accordance with TS 5.5.11, " Technical Specification Bases Control Program." An i affidavit supporting the facts set forth on this letter and its attachments is provided in Attachment I to this letter.

Background

As stated above, IP's April 19,1996 amendment request involved proposed changes to the requirements of the CPS TS that are currently applicable when moving g control rods in MODE 5. Movement of control rods in MODE 5 is considered a CORE ALTERATION. Currently, during CORE ALTERATIONS, the CPS TS impose ;gO\

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9608210235 DR 960315 ADOCK 05000461 PDR \

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U-602623 I Page 2 4

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! operability requirements on secondary containment, secondary containment penetrations l and wssociated automatic isolation instrumentation, secondary containment bypass leakage j path penetrations and associated automatic isolation instrumentation, the Standby Gas

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Treatment System (SGTS), and the main control room air conditioning, ventilation, and associated automatic isolation instrumentation. As stated in the Bases for these TS, during MODE 5 these requirements are provided to protect the public and the main

} control room personnel from the release of radioactive material in the event of a fuel handling accident.

i In addition to the previously noted TS requirements related to the secondary j containment and main control room boundaries, there are a number of other_TS

requirements that apply in MODE 5 with a control rod withdrawn. [As previously noted,

! control rod withdrawal in MODE 5 (i.e., with the reactor vessel head removed) is

{. considered a CORE ALTERATION). These additional TS requirements include

requirement! Mated to shutdown margin, source range neutron monitors, Reactor j Protection Sgtan (RPS) instrumentation, RPS power monitoring, control rod operability,

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and operability of the refuel position one-rod-out interlock. As stated in the Bases for '

i these TS, during MODE 5 these requirements are provided to preclude an int.dvertent l

criticality resulting from the withdrawal of multiple control rods and to effect automatic {

i insertion of the control rods in the event of an inadvertent criticality event. '

i f However, as stated in the Bases for CPS TS Limiting Condition for Operation

. (LCO) 3.9.2, " Refuel Position One-Rod-Out Interlock," the TS requirements associated

with shutdown margin and operability of the refuel position one-rod-out interlock are

[ provided to prevent criticality by preventing withdrawal of more than one control rod.

j With only one control rod withdrawn and shutdown margin within limits, the core will i remain suberitical, thereby preventing any prompt critical excursion. As stated in the j_ Bases for CPS TS LCO 3.10.3, " Single Control Rod Withdrawal - Hot Shutdown," the j control rod scram function enforced by the requirement for operability of various RPS l instruments provides backup protection in the event normal refueling procedures and the refueling interlocks fail to prevent inadvertent criticality during refueling.

Conclusions Based on the above, additional requirements to establish the secondary containment and main control room boundaries to protect against an inadvertent criticality as a result of control rod movement in MODE 5 are overly restrictive and contribute to unnecessary delay in refueling outage activitles. Specifically, venting of control rod drives following refueling activities but prior to reinstalling the reactor vessel head is considered a CORE ALTERATION and thus, requires the secondary containment and main control '

room boundaries to be established. As noted in IP's April 19,1996 amendment request, for RF-6 the schedule duration of the outage could be reduced by several hours with incorporation of this proposed relaxation.

U-602623 Page 3 IP's April 19,1996 amendment request, while retaining the requirements related to handling irradiated fuel, proposed deletion of" CORE ALTERATIONS" from the l Applicability statements of the TS requirements related to the secondary containment and l main control room boundaries previously identified. As an alternative to this approach, a ,

Special Operations LCO (i.e., LCO 3.10.10, " Single Control Rod Withdrawal - l Refueling")is being proposed. The proposed LCO 3.10.10 takes exception to the TS requirements related to the secondary containment and main control room boundaries as identified in IP's April 19,1996 amendment request, to permit control rods to be withdrawn one at a time by normal means for the purpose of venting control rod drives, exercising or performing scram timing, etc., provided all other control rods remain fully inserted and there are no other CORE ALTERATIONS in progress. Thus, the proposed LCO 3.10.10, while presenting the proposed relaxation in a different format, has the same effect as IP's April 19,1996 request.

IP has reviewed the Bases for No Significant Hazards Considerations contained in l IP's April 19,1996 amendment request and has concluded that the changes contained in this revision do not alter the bases or conclusions provided in those assessments.

Additionally, the changes contained in this revision do not alter IP's determination that the l proposed changes meet the criteria given in 10CFR50.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement. l l

As noted previously, approval of this request will potentially result in a reduction in the duration of RF-6. As a result, IP requests that this application continue to be reviewed on a schedule sufficient to support RF-6, which is currently scheduled to begin  :

October 13,1996. l Sincerely yours, Yc.4f 0 &A Wilfred Connell Vice President DAS/csm Attachments cc: NRC Clinton Licensing Project Manager NRC Resident OfIice, V-690 Regional Administrator, Region III, USNRC Illinois Department ofNuclear Safety

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Attachment I to U-602623 l

l Wilfred Connell, being first duly sworn, deposes and says: That he is Vice President of Illinois Power; that the application for amendment ofFacility Operating License NPF-62 has been prepared under his supervision and direction; that he knows the contents thereof, and that to the best of his knowledge and belief said letter and the facts contained therein are true and correct. l l

l l

l l

Date: This M day of August 1996.

Signed: MM dee#

Ifred Connell

(::::::::::::. ::::::::::,

STATE OF ILLINOIS l SS. *N M*

wemma.ame b

Nelsy P2Ec,Shh of Buls DE WITr COUNTY J f_MyCommissionEgims11/20M l Subscribed and sworn to before me this 156 day of August 1996.

CL 6.8LS (Notary Public)