U-601170, Application for Amend to License NPF-62,revising Tech Specs 3.0.4,4.0.3 & 4.0.4 & Tech Spec Bases 3.0 & 4.0 & Deleting Tech Specs Statements Which Presently Take Exception to Spec 3.04.Fee Paid

Application for Amend to License NPF-62,revising Tech Specs 3.0.4,4.0.3 & 4.0.4 & Tech Spec Bases 3.0 & 4.0 & Deleting Tech Specs Statements Which Presently Take Exception to Spec 3.04.Fee Paid

ML20151B795
Person / Time
Site:	Clinton
Issue date:	07/11/1988
From:	Hall D ILLINOIS POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20151B798	List: ML20151B809 U-601170, Application for Amend to License NPF-62,revising Tech Specs 3.0.4,4.0.3 & 4.0.4 & Tech Spec Bases 3.0 & 4.0 & Deleting Tech Specs Statements Which Presently Take Exception to Spec 3.04.Fee Paid
References
DPH-0640-88, DPH-640-88, GL-87-09, GL-87-9, U-601170, NUDOCS 8807210106
Download: ML20151B795 (6)

Text

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'U-601170 7, -

L47-88(07 - 11)-LP 1A.120

/LLINDIS POWER 00MPANY CLINTON POWER STAMON, P.O. BOX 678, CLINTON. ILLINOt$ 61727 DPH-0640-88 July 11, 1988 10CFR50.90 Docket No. 50-461 Document Control Desk Nuclear Regulatory Commission 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 l 10CFR50.91(b)(1), a copy of this request for amendment has been sent to the Illinois Department of Nuclear Safety as indicated below.

This proposed amendment requests revision to Technical 1 Specifications 3.0.4, 4.0.3, 4.0.4, and Technical Specification Bases Sections 3.0 and 4.0 In addition, this amendment deletes -

numerous Technical Specification statements which presently take exception to the provisions of Specification 3.0.4 These changes are based on the guidance provided by the NRC staff in Generic Letter 87-09 dated June 4, 1987. Attachment 2 to this letter provides a description of and justification for the requested changes including a basis for no significant hazards censideration. These changes do not affect IP's ability to safely operate CPS under its current license. An affidavit supporting the facts set forth herein accompanies this letter.

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, f00{

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U-601170 L47-88(07 -11 )-LP d' 1A.120 IP has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, significantly increase the types and amounts of effluents that may be released offsite, or significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, IP concludes that the proposed Technical' Specification changes meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirement for er Environmental Impact Statement.

Sincerely yours, 9

D. P. Hall Vice President GSL/krm Attachments l

t cc: NRC Resident Office NRC Region III, Regional Administrator NRC Clinton Licensing Project Manager Illinois Department of Nuclear Safety 1

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, to U-601170 STATE OF ILLINOIS COUNTY OF DEWITT DONALD P. HALL, being first duly sworn, deposes and says:

Triat he is Vice President of Illinois Power Company; that the provided information 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.

T DATED: This // day of July 1988 Signed:

Donald F. Hall Subscribed and sworn to before me this /// day of July 1988, b h: X Notary xl ($Public b ix/ b ~'u HOFFICI AL S E A Lil UNDA B chi M B!RLAIN My commission expires: -"'*"',$'l,'ffs"((En$'I.I',","d8 gy co 1 I

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• Attcchment 2 ,

to U-601170

& Page 1 of 46 Description and Justification for Changes Illinois Power (IP) is proposing changes to Clinton Power Station (CPS)

Technical Specifications 3.0.4, 4.0.3, 4.0.4, and Technical Specification Bases Sections 3.0 and 4.0. In addition, this amendment deletes numerous Technical Specification statements which presently take exception to the provisions of Specification 3.0.4. These changes are proposed in accordance with Generic Letter 87-09 which discusses recent initiatives undertaken in accordance with the NRC staff and the nuclear industry to improve Technical Specifications. The generic letter provides guidance for three specific problems encountered with the general requirements. on the applicability of Limiting Conditions for Operation (LCO) and Surveillance Requirements in Sections 3.0 and 4.0, and states that the NRC staff has concluded that these modifications will improve the Technical Specifications for all plants. IP has reviewed the generic letter and concludes that the proposed changes are an improvement over the existing CPS Technical Specification wording. The specific changes to Technical Specification 2.0.4, 4.0.3 and 4.0.4 are as follows:

1. Change Specification 3.0.4 to read:

3.0.4 Entry into an OPERATIONAL CONDITION or other specified condition shall not be made when the conditions for the Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not met within a specified time interval. Entry into an OPERATIONAL CONDITION or other specified condition may be made in accordance with the ACTION requirements when conformance to them permits continued operation of the facility for an unlimited period of time.

This provis.on shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements. Exceptions to these requirements are stated in the individual Specifications. ,

2. Change Specification 4.0.3 to read:

4.0.3 Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noacompliance with tne OPERABILITY requirements for a Limiting Condition for Operation. The time linits of the ACTION requirements are applicable at tne time it is identified that a Surveillance Requirement has not been performed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance when the allowable outage time limits of the ACTION requiremente are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Surveillance Requirements do not have to be performed on inoperable equipment.

3. Change Specification 4.0.4 to read:

4.0.4 Entry into an OPERATIONAL CONDITION or other specified applicable condition shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have been performed within the applicable surveillance interval or as otherwise specified.

This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements.

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' Attcchment 2 to U-6011/0

• Page 2 of 46 Due to the provisions of the revised Specification 3.0.4 as proposed, specific exceptions to this Specification, which are currently insluded in the ACTIONS listed under various Limiting Conditions for Operation throughout the Technical Specifications, will be removed. That is, in accordance with the generic letter, individual Specifications with ACTIONS permitting continued operation (for an unlimited period of time with no plant shutdown required) no longer need to indicate that Specification 3.0.4 does not apply. Marked-up copies of the affected Technical Specifications are attached.

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, (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.

I. The proposed change to Specification 3.0.4 permits plant startups (i.e. ,

mode changes) under conditions in which conformance to the ACTION requirements establishes an acceptable level of safety for unlimited continued operation of the facility. Currently, mode changes are permitted under the provisions of an ACTION requirement if a specific exception to Specification 3.0.4 is included with the ACTION requirement.

The proposed revision to Specification 3.0.4 eliminates the need for certain exceptions while preserving the intent of allowing mode changes when operating under the provisions of an ACTION (s) if the ACTION (s) permits continued plant operation. Because conformance to the provisions of such ACTIONS establishes an acceptable level of safety for unlimited continued operation of the facility, the proposed change to Specification 3.0.4 (and associated exceptions identified in the applicable ACTIONS of various Limiting Conditions for Operation) does not (1) involvc a significant increase in the probability or consequences of an accident previously evaluated or (2) involve a significant reduction in a margin of safety.

Since the proposed change is essentially administrative in nature and does not involve any changes to plant design or the introduction of any new failure modes, the proposed change does not (3) create the possibility of a new or different kind of accident f rom any previously 3

evaluated.

II. The proposed change to Specification 4.0.3 allows appropriate time for performing a missed surveillance before shutdown requirements apply to permit the performance of the missed surveillance based on considerations e.f plant conditions, adequate planning, availability of personnel, and she time necessary to perform the surveillance. The proposed change also l l

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• Attcchment 2 7 to U-601170 5 Page 3 of 46 eliminates potential conflicts that may arise when (1) the performance of a surveillance test is delayed upon entry into a new mode of operation under the allowance of an exception to Specification 4.0.4 (an exception to Specification 4.0.4 1s generally allowed when it is not possible to perform a surveillanca test until af ter entry into the applicable operational condition or mode), or (2) when the execution of an ACTION p'. aces the plant in an operational mode or condition such that the surveillances required for that mode would not have been performed within the required surveillance interval thus resulting in the condition of failure currently described in Specification 4.0.3. The inclusion of the 24-hour provision in Specification 4.0.3 as proposed should eliminate these apparent conflicts since it allows time for the applicable surveillance (s) to be performed.

The NRC' staff stated in the Generic Letter that it is overly conservative to assure that systems or components are inoperable when a surveillance has not been perforud. Therefore, allowing sufficient time to perform surveillances under such conditions that are adequate yet restricted-does not (1) involve a significant increase in the probability or consequences of an accident previously evaluated or (2) involve a significant reduction in a margin of safety. This is particularly true in view of the fact that the proposed change reduces the possibility of attempting to perform a surveillance (s) too quickly (in order to meet an ACTION time limit) which could increase the potential for operator error or challenges to safety systems.

Since the proposed change does not impact plant design, impose any new limits on piant process parameters, or introduce any new failure modes, the propcaed change does not (3) create the possibility of a new or differeat kind of accident from any previously evaluated.

III. The proposed change to Specification 4.0.4 is a clarification to permit passe.Je through or to operational modes as required to comply ;;ith Action Requirements even though an applicable surveillance requirement has not been performed for the mode or condition being entered. This  ;

clarification or provision should reduce the potential for plant upsets and unnecessary challenges to safety systems when attempts are being made to ensure that all Surveillance Requirements have been satisfied for the new mode of operation. The proposed change therefore in administrative in one sense (in that it resolves the apparent conflict between ACTIONS that require a mode change and Specification 4.0.4 which requires surveillances to be performed prior to entry into an applicable mode or condition) and yet may also enhance safe operation of the facility as described above. For these reasons, the proposed change does not (1) involve .i significant increase in the probability or consequences of an accident previously evaluated or (2) involve a significant reduction in a margin of safety.

Since the proposed change dou not impact plant design, itepose any new limits on plant process parameters, or introduce any new failure modes, 1 the proposed change does not (3) create the possibility of a new or different kind of accident from any previously evaluated.

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