RS-14-308, License Amendment Request to Revise Technical Specification 5.5.2, Primary Coolant Sources Outside Containment.

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

ML14321A882
Person / Time
Site:	Clinton
Issue date:	11/17/2014
From:	Simpson P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-14-308
Download: ML14321A882 (11)

Text

4300 Winfield Road

-411111111115f Warrerviiie. IL 60555 4111111111MMPr

'.on Generation 630 557 2000 Office RS-14-308 10 CFR 50.90 November 17, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

License Amendment Request to Revise Technical Specification 5.5.2, "Primary Coolant Sources Outside Containment" In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to Facility Operating License No. NPF-62 for Clinton Power Station (CPS), Unit 1. The proposed change would revise 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 revises the current frequency for integrated leak testing of "at refueling cycle intervals" to "at least once per 24 months." The change will also add a statement that allows the provisions of TS Surveillance Requirement (SR) 3.0.2 to be applicable to TS 5.5.2 integrated leak test requirements. This change is consistent with Technical Specification Task Force (TSTF) Traveler TSTF-299-A, "Administrative Controls Program 5.5.2.b Test Interval and Exception," Revision 0. This change also makes the CPS TS 5.5.2 consistent with Revision 4 of NUREG-1434, "Standard Technical Specifications General Electric BWR/6 Plants."

The attached amendment request is subdivided as follows:

Attachment 1 provides an evaluation of the proposed change.

Attachment 2 provides the marked-up TS page with the proposed change indicated.

The proposed amendment has been approved by the CPS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.

EGC requests approval of the proposed license amendment by November 30, 2015. Once approved, the amendment will be implemented within 30 days.

November 17, 2014 U. S. Nuclear Regulatory Commission Page 2 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), EGG is notifying the State of Illinois of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 17th day of November 2014.

Respectfully, Patrick R. Simpson Manager Licensing Exelon Generation Company, LLC Attachments:

1) Evaluation of Proposed Change

2) Markup of Technical Specifications Page cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector Clinton Power Station Illinois Emergency Management Agency Division of Nuclear Safety

ATTACHMENT 1 Evaluation of Proposed Change

Subject:

License Amendment Request to Revise Technical Specifications 5.5.2, "Primary Coolant Sources Outside Containment" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration 4.3 Conclusions

6.0 REFERENCES

Page 1 of 7

ATTACHMENT 1 Evaluation of Proposed Change 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to Facility Operating License No. NPF-62 for Clinton Power Station (CPS), Unit 1. EGC proposes to revise 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 revises the current frequency for integrated leak testing of "at refueling cycle intervals" to "at least once per 24 months." The change will also add a statement that allows the provisions of TS Surveillance Requirement (SR) 3.0.2 to be applicable to TS 5.5.2 integrated leak test requirements. This change is consistent with Technical Specification Task Force (TSTF) Traveler TSTF-299-A, "Administrative Controls Program 5.5.2.b Test Interval and Exception," Revision 0 (Reference 1).

Approval of this amendment application is requested by November 30, 2015, to support planning for refueling outage C1R16, scheduled for May 2016. Once approved, the amendment will be implemented in 30 days.

2.0 DETAILED DESCRIPTION On October 21, 2005, the NRC issued License Amendment No. 169 for CPS, Unit 1 (Reference 2). Under Amendment No. 169, the NRC approved the extension of the CPS operating cycles from 18 months to 24 months. CPS has been operating on 24-month cycles since that time.

TSTF-299-A, which was approved by the NRC on October 31, 2000, modified Improved Standard IS (ISIS) 5.5.2, "Primary Coolant Sources Outside Containment," to clarify the intent of refueling cycle intervals with respect to the system leak test requirements. This TSTF also revised IS 5.5.2 to allow application of the 25-percent scheduling flexibility extension provision of ISIS SR 3.0.2. This wording is currently reflected in NUREG-1434, "Standard Technical Specifications General Electric Plants (BWR/6)," (Reference 3).

Recently, an analysis was performed by EGC and it was determined that it would be cost beneficial to operate CPS on a 12-month cycle, thus requiring refueling operations on 12-month intervals. Starting in the spring of 2015, following startup from refueling outage Cl R15, CPS will begin annual operating cycles, with annual refueling outages. The C1R15 refueling outage will be a more traditional refueling outage consisting of both refueling activities and maintenance activities (i.e., "refueling/maintenance outages"). The following spring, in May 2016, refueling outage C1R16 will focus primarily on refueling activities with minimal maintenance activities (i.e., "refueling only outages"). It is being planned that the odd year refueling outages will be "refueling/maintenance outages" and even year refueling outages will be "refueling only outages." With this alternating pattern between refueling only outages and refueling/maintenance outages, the interval between refueling/maintenance outages will be 24 months.

This proposed license amendment is requested to maintain the current (i.e., 24 month) frequency for the CPS integrated leak test requirements for primary coolant sources outside containment. 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 Page 2 of 7

ATTACHMENT 1 Evaluation of Proposed Change 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 revised TS 5.5.2, would state:

"The program shall include the following:

a. Preventive maintenance and periodic visual inspection requirements; and

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

The provisions of SR 3.0.2 are applicable." provides a mark-up of the affected TS page for the proposed change.

3.0 TECHNICAL EVALUATION

CPS TS 5.5.2, "Primary Coolant Sources Outside Containment," is an administrative controls program to minimize leakage to levels as low as practicable, from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident. This program includes preventive maintenance, periodic inspections and leak tests for the identified systems. This program also requires that system leak tests for each system be performed at refueling cycle intervals or less.

This proposed revision to TS 5.5.2 is to require these tests be performed at least once per 24 months as opposed to refueling cycle intervals. As noted above, CPS will be transitioning to a 12 month fuel cycle beginning in the spring of 2015; performing a refueling outage every 12 months. Based on the current wording in TS 5.5.2 and the proposed 12 month fuel cycle, CPS would be required to perform integrated leak testing of the systems containing primary coolant outside containment on a 12 month frequency. Since EGC intends to continue performing refueling/maintenance outages every other year, the interval between refueling/maintenance outages will be 24 months. Therefore, the proposed change to requiring integrated leak tests at least once per 24 months ensures the testing is done during the planned 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. CPS has been performing integrated leak testing for the systems containing primary coolant outside containment on a 24 month frequency since the station transitioned to a 24 month cycle in October 2005. Presenting this requirement in this Page 3 of 7

ATTACHMENT 1 Evaluation of Proposed Change manner achieves consistency with similar surveillance requirements in the Technical Specifications.

Additionally, to be consistent with normal surveillance requirements that allow for a 25%

extension of the frequency in accordance with SR 3.0.2, the SR 3.0.2 allowance is also being proposed to be applied to TS 5.5.2. This is acceptable since TS 5.5.2 testing is considered a surveillance requirement. As stated in TSTF-299-A, since SR 3.0.2 only applies to TS LCO Sections 3.0 through 3.9, it is appropriate to add the explicit SR 3.0.2 statement to TS 5.5.2.

The application of the SR 3.0.2 allowance to CPS TS 5.5.2 ensures CPS consistency with the ISTS 5.5.2 provided in Reference 3.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36(c)(5), "Administrative controls," states that administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. This includes station programs required to be established, implemented and maintained. This change does not eliminate the requirement for a program to provide controls to minimize leakage from those portions of primary coolant sources outside containment that could contain highly radioactive fluids during a serious transient or accident. CPS TS will continue to comply with 10 CFR 50.36(c)(5).

This change will not reduce the effectiveness of the leak test requirements and it will still meet the intent of the requirements of Item III.D.1.1, "Integrity of Systems Outside Containment Likely to Contain Radioactive Material for Pressurized-Water Reactors and Boiling-Water Reactors," in NUREG-0737, "Clarification of TMI Action Plan Requirements." The CPS response to the NUREG-0737 requirement is documented in Reference 4.

EGC has determined that the proposed change does not require any exemptions or relief from regulatory requirements, other than the TS, and does not affect conformance with any regulatory requirements or criteria.

4.2 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to Facility Operating License No. NPF-62 for Clinton Power Station (CPS), Unit 1. The proposed change would revise Technical Specification (TS) 5.5.2, "Primary Coolant Sources Outside Containment." Specifically, the proposed change revises the current frequency for integrated leak testing of "at refueling cycle intervals" to "at least once per 24 months." The change will also add a statement that allows the provisions of TS Surveillance Requirement (SR) 3.0.2 to be applicable to TS 5.5.2 integrated leak test requirements. The purpose of this change is to support the transition to 12-month refueling cycles.

Page 4 of 7

ATTACHMENT 1 Evaluation of Proposed Change According to 10 CFR 50.92, "Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment 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.

EGG has evaluated the proposed change for CPS, Unit 1, using the criteria in 10 CFR 50.92, and has determined that the proposed change does not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change to the CPS, Unit 1, IS 5.5.2, "Primary Coolant Sources Outside Containment" program, does not involve a physical change to the plant or a change in the manner in which the plant is operated or controlled. The proposed amendment affects only the interval at which integrated system leak tests are performed, not the effectiveness of the integrated leak test requirements for the identified systems. The proposed change effectively results in the performance of the integrated system leak tests at the same frequency that these tests are currently being performed. Incorporation of the allowance to extend the 24-month interval by 25%, as allowed by SR 3.0.2, does not significantly degrade the reliability that results from performing the surveillance at its specified frequency.

Implementation of the proposed change will continue to provide adequate assurance that during design basis accidents, the containment and its components would limit leakage rates to less than the values assumed in the plant safety analyses.

Test intervals are not considered as initiators of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased by the proposed amendment. TS 5.5.2 continues to require the performance of periodic integrated system leak tests. As stated in TS 5.5.2, the required plan 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.

Therefore, accident analysis assumptions will still be verified. The proposed change does not impact the purpose of this plan. As a result, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the probability and consequences of an accident previously evaluated will not be increased by this proposed change.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Page 5 of 7

ATTACHMENT 1 Evaluation of Proposed Change Response: No.

The testing requirements, to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident, exist to ensure the plant's ability to mitigate the consequences of an accident and do not involve any accident precursors or initiators. The proposed amendment affects only the interval at which integrated system leak tests are performed; they do not alter the design or physical configuration of the plant. The proposed change does not involve a physical change to the plant (i.e., no new or different type of equipment will be installed) or a change to the manner in which the plant is currently operated or controlled.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change does not alter the manner in which safety limits, limiting safety system setpoints, or limiting conditions for operation are determined. The specific requirements and conditions of the primary coolant sources outside containment program, as proposed, will continue to ensure that the leakage from the identified systems outside containment is minimized. The proposed amendment provides operating flexibility without significantly affecting plant operation.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above evaluation, EGC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (c), and accordingly, a finding of no significant hazards consideration is justified.

4.3 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by the operation of CPS, Unit 1, in the proposed manner, (2) such activities will be conducted in compliance with the NRC's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

EGC has evaluated the proposed amendment for environmental considerations. The review has resulted in the determination that the proposed amendment would change requirements with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a Page 6 of 7

ATTACHMENT 1 Evaluation of Proposed Change significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22, paragraph (b),

no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Technical Specification Task Force (TSTF) Traveler TSTF-299-A, "Administrative Controls Program 5.5.2.b Test Interval and Exception," Revision 0, October 2000

2. Letter from K. N. Jabbour (U. S. NRC) to C. M. Crane (AmerGen Energy Company, LLC),

"Clinton Power Station, Unit 1 Issuance of an Amendment RE: Changes to Technical Specifications to Accommodate 24-Month Fuel Cycles (TAG NO. MC3295)," dated October 21, 2005 (NRC Accession No. ML052940480)

3. NUREG-1434, Revision 4, "Standard Technical Specifications General Electric Plants (BWR/6)," Revision 4, April 2012

4. CPS Updated Safety Analysis Report Appendix D, NRC Action Plan Item III.D.1.1, "Integrity of Systems Outside Containment Likely to Contain Radioactive Material" Page 7 of 7

ATTACHMENT 2 Markup of 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; and

b. Integrated leak test requirements for each system at rcfucling cycic intcrvalo or lcopleast once per 24 months.

The provisions of SR 3.0.2 are applicable.

(continued)

CLINTON 5.0-8 Amendment No. 164 I