U-601460, Application for Amend to License NPF-62,revising Tech Spec Definition of Core Alteration to Clarify Applicability & Scope of Definition Re Movement of Fuel,Sources or Reactivity Control Components

Application for Amend to License NPF-62,revising Tech Spec Definition of Core Alteration to Clarify Applicability & Scope of Definition Re Movement of Fuel,Sources or Reactivity Control Components

ML20245K184
Person / Time
Site:	Clinton
Issue date:	06/30/1989
From:	Jamila Perry ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20245K188	List: ML20245K191 U-601460, Application for Amend to License NPF-62,revising Tech Spec Definition of Core Alteration to Clarify Applicability & Scope of Definition Re Movement of Fuel,Sources or Reactivity Control Components
References
U-601460, NUDOCS 8907050044
Download: ML20245K184 (9)

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l- U-601460 L C; j L47-89 ( 06 -30 )-LP h ./ 8E.100a-ILLIN0fB P0WER ' COMPANY CLINTON POWER STATION, P.O. BOX 678, CLINTON, .lLLINOls 61727 1

June 30, 1989 l

10CFR50.90 l

Docket No. 50-461 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C.: 20555

Subject:

Clinton Power Station Proposed Ame.ndment of Facility Operatina License No. NPF-62

Dear Sir:

Pursuant to 10CFR50.90, Illinois Power Company (IP) hereby applies for.an amendment of Facility Operating License No. NPF-62 for Clinton Power Station. This request for amendment' consists of eight separate changes to the Technical Specifications which.are. predominately based on operating and refueling experience gained during the first fuel cycle. A  :

description and justification including a Basis For No Significant Hazards Consideration for each of the proposed change is provided in Attachment 3. In addition, an affidavit supporting the facts set forth in this letter and its attachments is provided in Attachment 1.

IP has reviewed the proposed Operating License changes  !

against the criteria of.10CFR51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, or significantly increase the amounts or change the types of effluents that may be released offsite, nor do they significantly increase individual or cumulative occupational radiation exposures.

Based on the foregoing,.IP concludes that the proposed Operating License changes meet the criteria given in 10CFR51. 22 (c) (9) for a categorical exclusion from the requirement for an Environmental Impact Statement.

Sincerely yours,

. S. Per j sistant Vice President [ p, 8907050044 DR 890630 -

ADOCK 05000461 i'k l PDC l

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U-601460 L47-89 ( 06-30 )-LP 8E.100a GSL/krm Attachments cc: NRC Clinton Licensing Project Manager NRC Resident Office Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety 1

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t. 4-l Attachment 1 to U-601460 $

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STATE OF ILLINOIS 4 COUNTY OF DEhITT J. Stephen Perry, being first duly sworn, deposes and says:

That he is Assistant 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.

DATED: This 30 day of June 1989 Signed: .

.S b m_

phe6 Perry Subscribed and sworn to before me this M day of June 1989.

bV1/LM .

Notary Public I My Commission Expires:

(1)Ltdl.klQOl 7 r-- --- -- -

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"0FFICIAL SEAL" ll l l

, Sharon E. Harris ll 4 Notary Public, State of IHinois l ll My Commission Expires 3/9/91 l>

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r Attachm:nt 2 to U-601460 Page 1 of 2 Summary of Technical Specification Chances This is a summary listing of all 8 change packages. Please refer to each individual change package for a complete description and justification including the Basis For No Significant Hazards Consideration.

Packare No. Description LS-87-001 This package contains a proposed change to clarify the definition of CORE ALTERATION by making it clear that " movement", including undervessel replacement, of incore instruments (including the Local Power Range Monitors) is H21 a CORE ALTERATION.

LS-87-020 Rev. 1 This proposed change revises the Technical Specification surveillance requirements for diesel generators. Revision 1 is actually a supplement to a package that was submitted October 30, 1987 in response to NRC recommendations discussed during NRC review of the original submittal.

LS-87-022 This package incorporates "3.0.4 exemptions" into the ACTION statements of particular Technical Specifications prescribing Emergency Core Cooling System (ECCS) and core decay heat removal (shutdown cooling) i requirements during Mode 5. The primary purpose of this change is to permit reactor ,

cavity / upper containment pool water level to l be raised or lowered or the reactor vessel '

head to be detensioned while operating under the provisions of the applicable ACTION statements. ,

LS-88-026 This proposed change removes the upper limit for the energy (heat) dissipation rates for the heaters in the Standby Gas Treatment and Control Room Ventilation systems.

LS-88-036 This package is submitted in response to an NRC mandate to consider certain testable check valves as containment isolation valves.

The proposed changes consist of adding and deleting certain valve numbers from Table 3.6.4-1 of the CPS Technical Specifications.

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, Page 2 of 2

LS-89-005 .This proposed change removes the OPERABILITY requirements for the. controls _in the' Remote Shutdown System associated with components used only for the steam condensing mode of Residual Heat Removal'(RHR). (IP has l'

committed to ngt utilize this.mede of RHR.)

LS-89-009 The changes proposed in this package would allow the minimum acceptable count rate for OPERABLE source range monitors (SRMs) to be reduced from 3 cps.to 0.7 cps provided an:

adequate signal-to-noise ratio exists.

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' ' LS-89-011 This package consists of a proposed change.to revise the description of the Facility Review Group (FRG) composition such that. specific job titles are deleted and a moct general description of the FRG is provided. TLis' would facilitate changes to the plant staff organization or changes to the applicable job titles themselves without requiring a license amendment.

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U-601460 4

Attachment 3 LS-87-001 LS-87-020 Rev. 1 l LS-87-022 LS-88-026 LS-88-036 LS89-005 -

LS-89-009 LS-89-011 i

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U-601460 LS-87-001 Prgs 1 of 5 Description and Justification for Proposed Change Clinton Power Station (CPS) proposes to revise the CPS Technical Specification definition of CORE ALTERATION to clarify the applicability and scope of the definition with respect to the movement of fuel, sources, or reactivity control components versus movement of incore instrumentation. Under the revised definition of CORE ALTERATION as proposed, movement of source range monitors (SRMs), intermediate range monitors (IRMs), local power ringe monitors (LPRMs), traversing in-core probes (TIPS) or special moveable detectors, including undervessel replacement, would not be a CORE ALTERATION.

IP believes this definition is consistent with the intent of the existing definition but the wording should be revised to make this clear.

The specific changes to the current Technical Specification definition are indicated on the attached marked-up page 1-2 from the CPS Technical Specifications. The principal changes are in the second sentence of the definition: .

(1) The sentence was revised to include the LPRMs in the list of incore instruments of which movement is not considered a CORE ALTERATION. This is based on the fact that, like the other incore instrumentation utilized per the BWR-6 design, an LPRM string is contained in a thimble / dry tube which is contained in a housing constrained by an assembly situated below the core plate and which provides a sealing surface under the reactor vessel. The thimbles are welded to the vessel and extend to the access area below the vessel. (Further details are provided in the CPS Updated Safety Analysis Report [USAR] Section 7.6.1.5.5.) LPRMs may thus be replaced or removed from below the reactor vessel in the same manner as other incore instruments (SRMs, IRMs, etc.) without disturbing the vessel internals or the vessel integrity, or removing the reactor head.

Furthermore, discussions with General Electric confirm that, like other incore instrumentation, removal and insertion of an LPRM has a negligible  ;

impact on cere reactivity. In addition, including LPRMs in the list of incore instruments for which movement is not considered a CORE ALTERATION is a change which has been approved for most BWR-6 plants.

1 (2) The word " normal" was removed and the phrase " including undervessel l replacement" was inserted. This change resolves the question of whether l or not SRM replacement, for example, constitutes " normal movement" of the l SRM(s). Many plants interpret " normal movement" to be broader in scope l than normal withdrawal or insertion. They interpret " normal movement" to )

also include replacement of the SRM since replacing the SRM requires {

l withdrawing the SRM and reinserting it into the core in the normal l i manner, i.e., from under the vessel, as part of the replacement process. l, Furthermore, when an SRM is withdrawn in the " normal" manner, it is l withdrawn to a point well below (30") the bottom of active fuel. With respect to the core, therefore, the configuration that exists when an SRM is withdrawn by " normal movement" is essentially equivalent to that which exists when an SRM is withdrawn further and removed for replacement. SRM availability is affected differently in the two cases; however, SRM availability is supported by those Technical Specifications dedicated to l I

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. U-601460 LS-87-001 Paga 2 of 5 ensuring SRM OPERABILITY and should not be a consideration with respect to the definition of CORE ALTERATION. This discussion essentially applies not only to the SRMs but to all of the incore instrumentation as well.

CORE ALTERATION is a specified condition identified in the Applicability section of a number of Technical Specification Limiting Conditions for Operation (LCOs). These LCOs impose additional requirements and restrictions on the plant which are appropriate for supporting activities such as refueling or control rod blade replacement. A review of these applicable LCOs indicates however that they should not be required to be in effect just to support undervessel movement of incore-instrumentation (into and out of their associated dry tubes for replacement or any other reason) especially since such movement does not affect the core configuration or reactivity as discussed earlier.

Consistent with the above changes, the words "incore instruments" were removed from the first sentence. This was done to eliminate the contradiction that would exist between what is stated in the first sentence, i.e.. that the i addition, removal, relocation or movement of incore instruments is a CORE ALTERATION, and what is conveyed in the second sentence, i.e., that movement of incore instruments (SRMs, IRMs. LPRMs. TIPS, etc.) is not a CORE ALTERATION. Since, as described previously, all of the CPS (BWR-6) incore instruments are contained in a fixed thimble / dry tube attached to the vessel bottom head and can only be manipulated in a similar manner from under the vessel, the term " movement" alone bounds any action or operation (i.e.,

removal, insertion and replacement) associated with the incore instruments.

Moreover, the words " addition, removal, relocation or movement" are collectively more applicable to the manipulation of fuel than to incore ins truments .

Due to the changes proposed for the CORE ALTERATION definition, IP also proposes to change CPS Technical Specification 3.9.5. This Specification requires that direct communication be maintained between the control room and refueling platform personnel during CORE ALTERATIONS (in OPERATIONAL CONDITION

5) except (during) " movement of incore instrumentation and control rods with their normal drive system." To be consistent with the amended definition of CORE ALTERATION as proposed, Specification 3.9.5 should be amended as shown on the attached marked-up copy of page 3/4 9-7 from the CPS Technical Specifications. That is, the Specification no longer neede to allow an exception for movement of incore instrumentation since movement of incore instrumentation is clearly not a CORE ALTERATION under the CORE ALTERATION definition as proposed.

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 I 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.

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.. U-601460 LS-87-001:

Pega 3 of 5 (1) The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated because the CPS reactor (BWR/6) design is such that the movement of incore instrumentation (i.e., SRMs, IRMs, LPRMs, TIPS, and special moveable

. detectors) -including withdrawal or insertion for the purpose of replacement, does not constitute an operation.that affects core. "

reactivity, that physically changes the core configuration, or that potentially degrades the condition of the reactor vessel with respect to its capability for containing reactor coolant; it therefore does not involve a significant increase in the probability or consequences of any of the accident scenarios associated with these considerations. The proposed changes to the CORE ALTERATION definition are regarded as a clarification to .the existing definition and do not change its intent.

(2) The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated in view of the fact that the proposed change to the Technical Specification definition of CORE ALTERATION is consistent with the intent of the current definition. Including the LPRMs (as provided by the BWR/6 design) in the list of those instruments for which movement is not considered to be a CORE ALTERATION does not create the possibility of a new or different accident since LPRM withdrawal and insertion is effectively no different than the insertion or withdrawal of any other incore instruments.

(3) The proposed. change does not involve a significant reduction in a margin of safety so far as a margin of safety applies to this change. The proposed change involves no changes to plant design and affects no setpoints or margins assumed in any accident analyses.

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