ML20237A192

Application for Amend to License NPF-62,changing Tech Specs to Allow one-time Exception to Surveillance Requirements for Testing Listed Containment Isolation & Pressure Isolation Valves.Fee Paid

ML20237A192
Person / Time
Site:	Clinton
Issue date:	12/10/1987
From:	Hall D ILLINOIS POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20237A194	List: ML20237A192 U-601084, Proposed Tech Specs Re Containment & Pressure Isolation Valve Surveillance Requirements
References
U-601084, NUDOCS 8712140322
Download: ML20237A192 (8)

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e U-601084 L47-87 G2 -10 ) Lp 1A.120 ILLINDIS POWER COMPANY IP CLINTON POWER $TATION, P.O. BOX 678. CLINTON, ILLINOIS 61727 10CFR50.90 December 10, 1987 Docket 50-461 Document Control Desk Nuclear Regulatory Commiscion Washington, D.C. 20555

Subject:

Clinton Power Station Proposed Amendment to Facility Operating License NPF-62

Dear Sir:

Pursuant to 10CFR50.90, Illinois Power Company (IP) hereby applies for an amendment of Facility Operating License NPF-62 Clinton Power Station (CPS). In accordance with 10CFR50.30, three signed originals and forty copies of this application are enclosed.

This amendment consists of a request for a one-time exception of the Technical Specification surveillance requirements for testing Containment Isolation Valves (CIVs) 1E12-F023, 1E51-F034, 1E51-F035, lE51-F390, 1E51-F391, IE12-F061, 1E12-F062, 1E51-F013 and Pressure Isolation Valves (PIVs) lE12-F023, lE51-F013, 1E51-F066 of Specifications 4.6.1.2.d and 4.4.3.2.2, respectively. The attachment to this letter provides a description and justification for the requested change including a Jasis for no significant hazards consideration. This change does not affect IP's ability to safely operate CPS under its current license. An affidavit supporting certification accolapanies this 1.atter.

In accordance with the provisions of 10CFR170.12 and 170.21, IP is enclosing a check made out to the U.S. Nuclear Regulatory Commission in the amount of $150,00 as payment of the application fee for this amendment.

re y yours, 8712140322 B71210 PDR ADOCK05000ggi P D. . Hall Vice President KBR/krm Attachments

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U-601084 L47-87 G2 40 )- LP 1A.120 cc: NRC Resident Office-NRC Region III, Regional Administrator NRC Clinton Licensing Project Manager Illinois Department of Nuclear Safety 1

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Attachment I to U-601084

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STATE OF ILLINOIS COUNTY OF DEWITT DONALD P. HALL, Being first duly sworn, deposes and says: That he is Vice President of Illinois Power Company; that the provided information to certify that this change to the Clinton Power Station (CPS) Technical Specifications 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 request and the facts contained therein are true and correct.

DATED: This/d day of December 1987 Signed:

Ddin11d P. Hall Subscribed and sworn to before me this//' day of December 1987.

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• Attachment 2 to U-601084 Page 1 of 11 PACKAGE NUMBER 1 The following two changes are being submitted to request exception to the requirements of the Technical Specifications. Change fl requests an exception to the leak testing requirements for three Pressure Isolation Valves. Two of these valves (IE12-F023 and IE51-F013) a"e also containment isolation valves (containment penetration No. 42). Chan32 #2 requests an exception to the Type "C" test requirements for eight containment isolation valves common to containment penetration No. 42. Detailed justification including a basis for no significant hazards consideration for each of the two changes is provided below. Figure 1 on page 11 shows a simplified schematic of the subject valves.

Reason and Justification for Chance #1:

IP is requesting a one-time exception to the Technical Specification surveillance requirement 4.4.3.2.2 regarding the leak testing of three Reactor Coolant System Pressure Isolation Valves, IE12-F023, IE51-F013, and IE51-F066.

The purpose of the Technical Specification is to demonstrate operability by leak testing these valves on an 18-month cycle. This testing is normally accomplished coinciding with a normal refueling cycle, and this testing requires the plant to be in cold shutdown. Based on an 18-month interval and the provisions of Technical Specification 4.0.2, valves IE12-F023 and IF51-F013 will require testing by May 17, 1988, and valve IE51-F066 will require testing by October 4, 1988.

FerforminF the required leak rate testing on these valves vill require the removal of the drywell head and the disassembly of the reactor head spray piping. In addition, disassembly of the head spray piping necessitates that a l reactor coolant system boundary leakage test be performed in accordance with the ASME code. IP estimates that these tasks will extend the spring 1988 maintenance outage by about one week, and cause additional personnel exposure of approximately one to two Man-Rem.

The first refueling outage is scheduled for the spring of 1989. Drywell head removal and a reactor coolant boundary leakage test will be required during this outage, because leak testing of these Pressure Isolation Valves will be 1 required during this outage in order to bring the leak test schedule for these valves into alignment with the fuel cycle. Therefore, the time to perform the required testing has been ace n nted for in planning the first refueling outage.

IP has determined that approval of this request does not represent a significant decrease in safety or system reliability. The plant design relies However, gross failure l on these valves for protection of low pressure piping.

of these valves is unlikely, and leakage testing provides little advance indication of imminent gross valve f ailure. Furthermore, the system design is such that any leakage that may develop over this interval can be readily detected by existing instrumentation. High pressure conditions in the Reactor Core Isolation Cooling (RCIC) suction piping, or the Residual Heat Removal (RHR) discharge piping are annunciated in the main control room. RCIC suction pressure and RHR discharge pressure indications are also available in the main control room. These instruments are calibrated in accordance with the Clinton

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o Attachment 2 to U-601084

' Page 2 of.11 Power Station maintenance program. Procedures are in place to direct operator '

actions to mitigate any potential over-pressurization of this low pressure piping. In addition, the low pressure piping in these systems is protected '

from over-pressurization by relief valves. If leakage were to occur, the low pressure piping would not be jeopardized.

These valves have not required maintenance since they were last tested.

(IE12-F023 and IE51-F013 were tested on June 27, 1986 and IE51-F066 was tested on November 14, 1986.). These valves are tested for operability at cold shutdown per ASME requirements, and to date, test data shows acceptable Similar valves-will be tested during leakage rates from all of these valves.

the spring 1988 maintenance outage, and any excessive leakage or other degraded valve conditions indicative of a generic condition will be evaluated at that time.

Based on these considerations (plant conditions more supportive in spring 1969 outage for this testing, potential schedule impact to the spring 1988 maintenance outage, and ALARA considerations), the benefit to public health and safety gained by leak testing of these valves during the spring 1988 maintenance outage as opposed to the spring 1989 refueling outage is not apparent.

Basin f or No Significant Hacards Consideration According to 10CFR50.92, a proposed change to the license (Technical Specifications) involves no significant hazards consideration if operation of the facility in accordance with the proposed change wculd not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind cf accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

(1) It has been determined that the proposed change dees not involve a significant increase in the probability or consequences of an accident previously evaluated because the proposed change for postponing leak testing should not increase the probability of gross valve failure and the ccnsequent intersystem LOCA. Any small leakage that could develop over this interval would not jeopardize low pressure piping.

Additionally, should leakage occur, the plant is instrumented to detect it.

(2) The proposed change does not create the possibility cf a new or different kind of accident from any accident previously evaluated. No new accident scenarios are credible based on the rescheduling ef leakage testing alone. This change will make no physical change to the plant configuration and no new mode of plant operation will be implemented by this change.

(3) It has been determined that the proposed change does not involve a significant reduction in a cargin of safety. The proposed schedule for leak testing will not provide significantly less indication of a and potential for gross valve failure, and the plant design todiminished.

detect provide piping protection for over-pressurization is not

o Attachmene 2 to U-601084 Page 5 of 11 Reason and Justification for Change #2:

IP is requesting a one-time exception for Technical Specification 4.6.1.2.d regarding leak-rate testing of Containment Isolation Valves, IE12-F023, 1E51-F034, IE51-F035, 1E51-F390, 1E51-F391, IE12-F061, 1E12-F062, and IE51-F013. This sill allow exception of these testing requirements until the first refueling outage.

The purpose of the existing Technical Specification is that the subject valves be leak tested on a 24-month interval corresponding with the plant being in a COLD SHUTDOWN condition. IP intends to perform this surveillance at an interval corresponding to a normal refueling cycle. Based on the previous test completion date, these valves will require testing by October 21, 1968.

Performing the leak testing on these valves will require the rereval of the drywell head and the disassembly of the reactor head spray piping to allow installation of a blind flange as an inboard test boundary. Reassembly of the reactor head spray piping will require that a reactor coolant system boundary leakage test be performed in accordance with the ASME code. IP estimates that these tasks would extend the spring 1988 maintenance outage by about one week, and cause additional personnel exposure of approximately one to two Man-Rec.

The first refueling outage is scheduled for the spring of 1989. Drywell head removal and a reactor coolant boundary leakage test will be required during this outage. Leak testing of these Containment Isolatien Valves will also be performed during this outage in order to bring the test schedule for these valves into alignment with the fuel cycle. Therefore, the time to perform the required testing has been accounted for in planning the first refueling outage.

The containment leakage rate is primarily affected by ecyipment wear and maintenance. Isolation valves typically see little usage (especially test connections, vents and drain valves) except for periodic operability testing.

This leads to little degradation of ecuipment or increase in the leakage rate.

From October 21, 1966 to the spring 1989 refueling outape, these valves will be subjected to minimal wear.

Redundancy regarding primary containment isolation is provided by two isolation valves in series or one isolation valve bounded by a closed loop outside containment. Consequently, a reduction in the effectiveness of one valv, to provide a seal would not itself compromise containment integrity.

Deterioration of the overall integrity of the containment penetrations is normally a gradual process. Considering the redundancy of the isolation barriers, the short duration of the requested extension of the testing interval and the limited number of valves affected, any reduction in the containment integrity during the extension period would be negligible.

These valves have not required maintenance since last tested on October 21, 1986. These valves are tested during cold shutdown, and to date, data from past testing shows leakage to be well within acceptable limits. Similar valves will be tested during the spring 1988 maintenance outage, and any excessive leakage or other degraded valve conditions indicative of a generic condition will be evaluated at that time.

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' Attachment 2 to U-601084 Page 6 of 11 Basis for No Significant Hazards Consideration According to 10CFR50.92, a proposed change to the license (Technical Specifications) involves no significant hazards consideration if operation of the facility in accordance with the proposed change would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (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.

(1) It has been determined that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated because:

a) The most recent test of the valves was performed satisfactorily. No significant increase in the probability of equipment failures is postulated for the short, extended time-period effected by the deferred testing, b) The LLRT testing provides verification of valve seating integrity and does not provide assurance that the valve actuates (either automatically or manually) to its isolation position. Other surveillance are performed to verify the isoletion function for the applicable valves (1E51-F013 and IE12-F023) . The test intervals associated with these surveillance will not be affected by the proposed change.

(2) The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed change introduces no new modes of operation, failure modes or other changes to any equipment.

(3) It has been determined that the proposed change does not involve a significant reduction in a margin of safety because:

a) The requested extension does not significantly increase the specified surveillance frequency.

b) The requested amendment concerns schedule relief for surveillance testing of a very limited number of containment isolation valves associated with only one containment penetration.

c) Leak test acceptance criteria are not affected by the proposed change.

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