U-600821, Application to Amend License NPF-55,revising Tech Spec Section 3/4.7.2 to Change Recirculation Sys Air Flow Acceptance Criteria for Control Room HVAC Sys

Application to Amend License NPF-55,revising Tech Spec Section 3/4.7.2 to Change Recirculation Sys Air Flow Acceptance Criteria for Control Room HVAC Sys

ML20207Q490
Person / Time
Site:	Clinton
Issue date:	01/20/1987
From:	Hall D ILLINOIS POWER CO.
To:	Butler W Office of Nuclear Reactor Regulation
Shared Package
ML20207Q491	List: ML20207Q503 U-600821, Application to Amend License NPF-55,revising Tech Spec Section 3/4.7.2 to Change Recirculation Sys Air Flow Acceptance Criteria for Control Room HVAC Sys
References
U-600821, NUDOCS 8701270425
Download: ML20207Q490 (7)

Text

T U- 600821 8E.110 L30-87(01-20)-L

/LLINDIS POWER COMPANY CLINTON POWER STATION. P.O. BOX 678. CLINTON. ILLINOIS 61727 JAN 201987 Docket No. 50-461 Director of Nuclear Reactor Regulation Attention: Dr. W. R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Clinton Power Station Proposed Amendment of Facility Operating License No. NPF-55 Under Exigent Circumstances

Dear Dr. Butler:

Pursuant to 10CFR50.90, Illinois Power Company (IP) hereby applies for an amendment of Facility Operating License No. NPF-55 for Clinton Power Station (CPS). In accordance with 10CFR50.30, three signed originals and forty copies of this application are enclosed.

The purpose of the proposed amendment is to change the recirculation system air flow acceptance criteria for the Control Room HVAC System (VC) from 62,500 CFlt i 10% to 64,000 CFM i 10%. This requires a revision to Section 3/4.7.2 of the Low Power Technical Specifications (Appendix A to Facility Operating License No. NPF-55). The attachments to this letter identify the requested change which is the subject of this application for an amendment and provide an analysis and justification for issuance of the amendment. As explained in attachment 1, the requested amendment involves no significant hazards consideration.

In letter U-600469 dated March 12, 1986, IP requested to defer the preoperational phase installation of charcoal and testing of the VC charcoal filters until after Fuel Load. Authorization from the NRC was aparoved in a letter dated July 7, 1986. Since issuance of t'Te operating license, the VC system makeup and recirculation filter units' charcoal absorbers have been filled and preoperational testing is complete. The results of the testing show that the recircuintion flow rate in Train B of the VC system meets the value present in the existing CPS Mo\

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U-20821 8E.110 L30-87(01-20)-L Technical Specifications (TS): however Train A does not.

The train A recirculation flow rate slightly exceeds (by approximately .8%) the current CPS-TS value. In review of the design of the VC system, the as-built configuration needs no physical modification to meet the requirements of design as depicted in the FSAR Sections and CPS-TS. In summary, both trains satisfy the VC system design exceat for differences in flow. To achieve consistency between the CPS-TS and the as-built configuration of the VC system, the value for the recirculation system flow rate must be changed.

This proposed amendment involves no significant hazards considerations therefore, expedited treatment and consideration of this amendment application under exigent circumstances is requested as provided for in 10CFR50.91(a)(6). Exigent circumstances exist because the proposed amendment is required for CPS to achieve Initial Criticality due to deferred testing, the as-built flow could not be determined prior to completion of testing, and thus impact on Initial Criticality could not be assessed prior to receipt of the Operating License. The Initial Criticality milestone could be delayed if the proposed amendment is not granted, until after the normal 30-day comment period expires, per the provisions of 10CFR50.91(a)(2).

Following NRC approval of this license amendment, IP will revise, as appropriate, CPS Final Safety Analysis Report (FSAR) subsections 9.4.1, 6.4, 15.6.5.5.3 and Chapter 11 during the annual FSAR update process.

This change to CPS-TS has been reviewed and is consistent in all material aspects with the FSAR as amended, the SER and its Supplements No. 1-7 and the as-built plant.

An affidavit relating to this certification accompanies this letter.

Illinois Power Company considered two alternatives to bring train A of the VC system into compliance with the current value of the Technical Specifications. The first alternative consisted of installing a perforated plate into the VC filter unit OVC07SA. However, since there is no technical justification and due to additional costs and schedule impact (5 weeks), this alternative was eliminated.

The second alternative consisted of rebalancing the entire VC system train A. Again, reasons conciating of the impact on the project schedule (6 weeks) and reassignment of personnel being currently used to complete other tests were considered and this alternative was also eliminated. The third alternative is the subject of this request which if granted, will not delay the startup and initial criticality of Clinton Power Station.

U- 600821 8E.110 130-87(01-20)-L If you have any questions or require additional -

information, please contact me.

Sincerely yours, D. . Hall Vice President TLR/bsa. .q !; -

o Attachments cc B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Office Regional Administrator, Region'III, USNRC Illinois Department of Nuclear Safety 4

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c. i- State of Illinois I, D. P. Hall, being first duly sworn, do hereby affirm that I am an officer of Illinois Power Company that I have executed j

the foregoing documents that the statements made in the document x and its attachments are true and correct to the best of my knowledge, information, and beliefs and that I am authorized to e execute this document on behalf of Illinois Power Company.

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~Attachm2nt I to U-600821 Page 1 of 3 Proposed Amendment to Facility Operating License No. NPF-55: Control Room Ventilation Sys';em Description of amendment request:

The proposed amendment would modify Section 3/4.7.2, " Control Room Ventilation System," of the.Clinton Power Station Low Power i Technical Specifications (see Attachment 2 for proposed changes).

The modification will change the acceptance criteria for the. .

Control Room HVAC System (VC),'from 62,500 CFM i 10% to 64,000 h CFM i 10%. This is because the current acceptance criteria of 62,500 CFM i 10% is not achievable on both trains of the system. ,

i The value of 62,500 CFM was placed in the. CPS-TS as a preliminary value based on calculated flows. The initial calculation utilized artificial flow resistance values for the components which were initially deferred from testing prior to receipt of i the Low-Power Operating License. The 3roposed value of 64,000 '

CFM 10% is representative of the as-3uilt configuration of both trains of the VC system. This modification to the CPS Low Power Technical Specifications is required before CPS can achieve Initial Criticality, since this system must be OPERABLE prior to entry into Operating Condition (Mode) 2 If the proposed amendment is granted: ,

.(A) The CPS facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission:

4 (B) There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the' health and safety of the public, and (ii) that such activities will be conducted in compliance with '

the Commission's regulations: and (C) The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of

!. the public.

Basis for no Significant Hazards Determination:

The proposed change does not involve a significant hazards consideration because operation of Clinton Power Station in accordance with this change would not:

(1) involve a significant increase in the probability or j consequences of an accident previously evaluated.

Calculations of thyroid dose for Control Room Operators, for j

i

Attachm:nt 1 to U-600821 Page 2 of 3 the proposed change, show a slight decrease in the calculated dose due to recirculating a higher percentage of Control Room Air (relatively less contaminated than outside air during the Hi-Rad mode) through the filter unit.

Therefore this proposed change would decrease the consequences of an accident previously evaluated. Also, the proposed change would not impact the probability of any accident previously evaluated.

(2) create the possibility of a new or different kind of accident"from any previously analyzed. It has been determined that a new or different kind of accident will not be possible due to this change. An increase of VC system recirculation air flow does not create the possibility of a new or different kind of accident. This change does not constitute a change to plant equipment or, except for procedure test acceptance criteria, plant procedures.

(3) involve a significant reduction in a margin of safety. An increase in the VC system air flow will not reduce the margin of safety because the initial control room design was for a two unit control room utilizing a recirculation flow of approximately 71,000 cfm, the revised analysis for the thyroid dose has shown an overall decrease, and the analysis for chloride removal has shown a slight decrease from the values described in the Final Safety Analysis Report (FSAR).

These statements are supported by the 10CFR50.59 review, which considers the potential impact on the plant design basis accident analysis.

The VC system air flow acceptance criteria was initially determined based on a combination of the requirements of providing adequate air flow to remove radioactive contaminants and the air flow needed to meet the requirements for design. The requirement to adequately remove radioactive contaminants is not affected by this change. However, due to overly conservative assumptions involving assignment of initial flow resistance factors in the VC system, this change is required for both trains to meet the operability requirements of the CPS-TS. Therefore, the change in the acceptance criteria for the VC system may be considered a relief from an operating restriction that was imposed because acceptabic operation was not yet demonstrated.

Based on evaluation of Startup and Deferred Preoperational Test results, it has been determined that the increase in airflow does not have any adverse impact on system performance. This evaluation was conducted in accordance with the requirements of 10CFR50.59, Changes, tests and experiments. This review considered the criteria for all modes of system operation and the Main Control Room noise level requirements for the VC system. As such, all design requirements are fulfilled with the as-built system configuration.

Attachm:nt 1 to U-600821 Page 3 of 3 The proposed amendment will not have an impact on the environment. The effect of the proposed change will be a slight decrease in calculated thyroid dose for the Control Room operators and a slight decrease in the chlorine concentration which is within the limits of Regulatory Guide 1.95.

Therefore based on the above considerations, CPS has determined that this change does not involve a significant hazards consideration.

The proposed change to the CPS Low Power Technical Specification is under exigent circumstances, and expedited treatment and consideration is requested. Exigent circumstances exist because the proposed change is required prior to declaring the VC system cperable which is needed to support CPS Initial Criticality.

Adhering to the normal 30-day comment period under the provisions of 10CFR50.91(a)(2) could delay the CPS Initial Criticality milestone. This potential delay is based on IP's currently forecasted schedule for Initial Criticality of as early as January 25, 1987. Therefore, it is requested the proposed amendment be processed under the provisions of 10CFR50.91(a)(6) for erigent circumstances. Illinois Power has used its best effort to make a timely filing of the amendment application and could not have avoided, under normal circumstances, the condition where the as-built flow rate differed from the flow rate provided in the CPS-TS until Preoperational Testing was complete.

Therefore, consideration of this change under the exigent circumstances is appropriate.

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