U-602025, Forwards Replacement Pages for TS 3/4.3.7.1, Radiation Monitoring Instrumentation & 3/4.3.9, Plant Sys Actuation Instrumentation Contained in 910920 Amend Request,As Result of Questions/Comments from NRC During Review

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Forwards Replacement Pages for TS 3/4.3.7.1, Radiation Monitoring Instrumentation & 3/4.3.9, Plant Sys Actuation Instrumentation Contained in 910920 Amend Request,As Result of Questions/Comments from NRC During Review
ML20114A951
Person / Time
Site: Clinton Constellation icon.png
Issue date: 08/17/1992
From: Spangenberg F
ILLINOIS POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20114A952 List:
References
U-602025, NUDOCS 9208240160
Download: ML20114A951 (9)
v • d • e


Text

. .. .

U 602025 L47-92(08-17)LP

. BE.100a tuos Power Ccmpany Clinton Power Sta%n

, P.O Ib 678 C1mton, il t I 72 ?

TtA 217 935-SPB1 POWER August 17, 1992 10CFR50.90 Docket No. 50 461 Document Control Desk Nuclear Regulatory Commission -

Washington, D.C. 20555

Subject:

Clinton Power Station Revision to Previously Submitted Proposed Amendment of Facility Opert tint License No. NPF-62

Dear Sir:

By letter dated September 20, 1991 (reference U-601871), Illinois Power (IP) applied for amendment of Facility Operating License No. NPF- ,

62, Appendix A - Tecnnical Specifications, for Clinton Power Station (CPS). That reqtest consisted of proposed changes to the CPS Technical Specifications to incorporate reliability-based improvements to instrumentation Action Statements and surveillance test intervals based on Topical Rep cts which were previously submitted to the NRC by the Bolling Wat_r Peactor Owners' Croup (B'JROC) . However, as a result of questions / comments received from the NRC during their review of IP's request, additional clarifications /revicior.s have become necessary.

Attachment 1 to this letter contains the additional clarifications as well as a description and justification for the additional proposed changes. Attachment 2 to this letter cortains replacement pages for the af fected marked-up pages f or Technical Specification 3/4.3. 7.1,

" Radiation Monitoring Instrumentation," and 3/4.3.9, " Plant Systems Actuation Instrumantation," contained in IP's September 20, 1991 request (i.e., pages 33, 34, and 35 through 39 of Attachment 3 to U-601871).

IP has reviewed the Bases for No Significant Hazards considerations contained in IP's September 20, 1991 amendment request and has concluded that the additional changes contained in this revision do not alter the bases or conclusions provided in those assessments.

Additionally, the changes contained in]this revision do not alter IP's l

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i af determination that:the proposed' changes meet the criteria given la 10CFR50.22(c)(9) for a categorical exclusion.from the requirement for an LEnvironmental Impact Statement, Sincerely yours

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F. A, pange erg, 11 Manager - Licensing &~ Safety

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. Attachments cc: Regional Administrator, Region III, USNRC NRC. Clinton Licensing Project Manager NRC Resident Office,-V-690

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ce So Attachment 1-to U 602025-LS 88-042- l 1 Page 1 of 7

.3.

As a result of' questions / comments - received from the NRC during their review of IllinoisLPower's (IP's)-September 20, 1991 amendment request (reference U 601871):regarding reliability-based improvements to instrumentation JAction Statements and surveillance test intervals ,- additional clarifications / revisions have become necessary. These clarifications / revisions are related to the requirements for the followin5 '

instrumentation: (1) the Reactor Core Isolation Cooling (RCIC) system ,

actuation instrumentation, (2) the control rod block instrumentation, (3) radiation monitoring instrumentation, and (4 plant systems actuation

' instrumentation. Each-of these groups of requirements are discussed separately'below.

In addition, the NRC reviewer requested that IP confirm that the analysis documented in NEDC 30851P, " Technical Specification Improvement Analyses jfor BWR Reactor Protection System," for-the BWR/6 solid-state design

-supports relaxing-the Channel Functional Test frequency from monthly to .,

quarterly'for'the Manual Scram Functional Unit. IP confirmed with Genertl Electric that the Channel Functional Test frequency for the Manual Scram Functional Unit was assumed to be quarterly'in the model used for the analysis documented in.NEDC-30851P.

1. Technical Snecification 3/4.3.5. " Reactor Core Isolation Coolinn o System Actuation Instrumentation" TheJustification for IP') proposed changes to.the RCIC system

' actuation instrumentation requirements was provided in Part V of E Attachment 2 to IP's September 20, 1991 amendment request (reference page 28 uf 33). -IP's amendment request stated that the proposed

[

H changes were included in the Boiling Water Reactor Owners' Group

.(BWROG)fanalysis'of emergency. core cooling system (ECCS). actuation -

instrumentation-contained in NEDC-30936P, "BVR Owners' GroupL LTechnicals Specification Improvement Methodology (with Demonstration L for BWR ECCS. Actuation Instrumentation) Part-2." Howeier, model Technical Specification changes _ forL the RCIC actuation

-instrumentation.were not opecifically included in NEDC-30936P (Part

~

-2) . ?IP's-September 20, 1991- amendment request noted that model Technical Specification _ changes for the RGIC actuation h

H tinstrumentation were subsequently-provided_by the BWROG.in GENE-770-

~0 6-1, " Bases - for Changes to = Surveillance Test Intervals and Allowed

_ _0ut-of-Service Times for Selected Ins trumentation Technical Specifications." IP referenced the analyses provided in NEDC 30936P (Pait 2)L and -GENE-770-06-1 as the basis for the proposed changes to

-the RCIC:autuation instrumentation requirements.

JAdditional analyses and model: Technical Specification changes for the RCIC actuationiinstrumentation~were provided by:the BVROG in CENE-770-06-2, " Addendum to Bases for. Changes . to Surveillance Test

> Intervals .and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifica~!ons." IP has reviewed the-

. analyses presentedLin CENE-770.-06-2 and concluded that these tesults-are also directly applicable to CPS. The model Technical

, _ Specifications fur the BWR/6 solid-state plant (which were provided

- .. _. . - - - - _ - _ - - - - _ = _ ,

. . . ._- - . - . - . _. . . - - - . ~ . - - - ~ _ - --~---

Attachment 1

, to U-602025 LS-88-042 lage 2 of 7 in Appendix C of GENE 770-06-2) are identical to the proposed changes provided in IP's. September 20, 1991 amendment request. As a result.

-IP has determined that GENE-770 06-2 also providas justification for the changes to Technical Specification 3/4.3.5 proposed in IP's September 20, 1991 amendment request.

2. Technical Speci fication 3/4.3.6. "

Control Rod Block Instrumentation" The changes to Technical Specification 3/4.3.6 proposed in IP's September 20, 1991 amendment request are discussed in two separate locations in that request, Part III (reference page 12 of Attcchment

2) and Part V (reference page 29 of Attachment 2). Attachment 2, Part III, Item 1 of IP's September 30, 1991 amendment request discusses proposed changes to the allowable out-of-service time ( A0T)-

for performing surveillances. IP's amendment request stated that-this proposed change was included in the BWROG analysis docamented in t -NEDC-30851P, Supplement 1, " Technical Speciftcation Improvement l Analysis for BVR Control Rod Block Instrumentation." However, proposed changes to the surveillance A0T were actually included in GE';P-770-06-1. Thus, this proposed change should have been discussed under Part V of IP's amendment request. [The proposed change to the surveillance A0T was specifically addressed in GENE-770-06-1 by the addition of footnote "*" to Surveillauce Requirement 4.3,6 (reference GENE 770 06 1 pages 19 s Td A-40) . ]

In addition, the justification for the proposed changes to the ,

control rod block instrumentation requirements discussed in Part V of IP's September ~20,=1991 amendment request (reference page 29 of -

p Attachment 2) also contains an error in the BWROG report reference, i:

IP'sfamendment-request stated that the changes proposed in Part V Lwere bounded by the bases provided.in NEDC-30851P, Supplement 2.

However, this reference should have been NEDC-30851P, Supplement 1 sint Supplement 1- supports proposed changes to control rod block instrumentation requirements. (Supplement 2 addresses proposed changes to containment isolation instrumentation requirements.)

-3. Technical Specification 3/4.3.7.1. " Radiation Monitorinr.

Instrumentation" Proposed. changes to Technical Specification 3/4.3.7.1, which are j _ based onLGENE-770-06-1, were described in Part V of Attachment 2 to l _ IP's September _20,fl991 amendment request (reference pages 25 and 29). GENE-770-06-01 provided the justification for changing the Channel Functional Test Frequency for the main control room air intake' radiation monitors from monthly-(M) to quarterly (Q) based on the analyses documented in NEDC-31677P, " Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation."

NEDC-31677P also supported changes to the repair A0T for containment L isolation instruments" from one hour to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, CENE-770-06-01 did not specifically identify that the repair A0T for the main control room air intake radiation monitors could be increased.

- Notwithstanding, based on the main control room air intake radiation .

monitoring instrumentation arrangement being similar to the containment and reactor vessel isolation control system (CRVICS)

~

radiation monitoring instrumentation, IP concluded that the analysis .

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F Attachment.1

, to U 602025 LS-88-042 Page 3 of 7 of the isolation actuation instrumentation provided in NEDC-31677P supports similar surveillance test interval (STI) and A0T changes to the Technical Specifications for the main control room air intake radiation monitors.

During subsequent conversations with the NRC, it was determined that, as no specific change to the repair A0T was identified for the main control room air intake radiation monitors and the referenced Technical Specification in GENE-770-06 1 was "BWR 6 Improved Technical Specification (ITS), Control Room Fresh Air Instrumentation" (reference GENE 770-06-1 page 18), the NRC would only agree to the repair AOT provided in the BWR 6 Improved Technical Specifications. -

IP continues to believe that the analysis of the isolation actuation

-instrumentation provided in NEDC-31677P supports similar STI and A0T changes to the Technical Specifications for the main control room air intake radiation monitors. How3ver, IP now proposes that the repair A0T for these radiation monitors be increased from one hour to six

' hours (rather than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) to be consistent with the latest draft of.the BWR 6 Improved Technical Specifications (NUREG-1434).

Therefore, IP requests that the marked up pages from Technical Specification 3/4.3 7.1 contained in.IP's September 20, 1991 amendment request-(Attachment 3 pages 33 and 34) be superseded by the marked up pages 1 and 2 of Attachment 2 of this letter.

1-

4. Technical Specification 3/4.3.9. " Plant Systems Actuation Instrumentation" Proposed changes to Technical Specification 3/4.3.9, which are based on GENE 770-06-1, were described in Part V of Attachment 2 to IP's September 20, 1991 amendment request (reference pages 25 and 30). _

CENE-770-06 1 provides justification for increasing the repair A0T

~

for these instruments "if takinn out the channel does not cause loss of the trip function." During their review of IP's amendment request, the NRC ncted that the proposed changes to the repair A0Ts for the containment spray system and the suppression pool makeup system actuation instrumentation of Technical Specification 3/4.3.9 are not consistent with this limitation of GENE-770-06-1. As a-

-result, IP has re-evaluated the proposed changes to the repair A0Ts -

for Technical ~ Specification 3/4.3.9 and determined that the marked-up pages-from Technical Specification 3/4.3.9 contained in IP's September 20, 1991 amendment request (Attachment 3 pages 35 through

39) should-be superseded by the marked-up pages 3 through ? of

-Attachment 2 to this letter. [The additioaal changes proposed by

-this revision are identified by double change bars.] Justification for each-of these proposed changes is discussed below.

Containment Spray System

_The containment spray system is an operating mode of the residual heat removal (RHR) system and is a containment heat removal system.

The containment spray system is described in CPS Updated Safety Analysis Report (USAR) Section 6.2.2. As described in the USAR, during containment spray system operation, water is drawn from'the

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Attachment 1 to U-602025 LS-88 042 Page 4 of 7 i

suppression pool, pumpec through one or both RHR heat exchangers (which removes heat to the emergency service water system), and is 3 delivered to the containment spray headers. Most of the water discharged from the containment spray headers will return to the suppression pool, where it is recirculated through the spray headers.

The purpose of this mode oi RHR is to cool non-condensible gases and condense steam which may be present in the containment following a loss-of-coolant accider- (LOCA) in order to reduce containment pressure and prevent atainment from exceeding its design limits.

The actuation logic for the containment spray system at CPS is described in USAR Section 7.3.1.1.4.4. As described in the USAR, the _

containment spray system can be actuated either automatically or manually. The system is automatically actuated approximately 10 minutes af ter receiving a LOCA signal (which is provided by two high drywell pressure and two low reactor water level, level 1 signals combined in a one-out-of-two-twice logic configuration) provided a high drywell pressure condition (two signals combined in a one-out-of-two logic arrangement) and a high containment pressure condition (two signals combined in a one-out-of-two logic arrangement) exist concurrently. In addition, the Division 11 system includes an additional 90-second time delay to ensure that both containment spray loops do not initiate simultaneousif. The system can be manually actuated by arming and depressing a single manual pushbutton coincident with the above high drywell pressu o condition (or.e-out-of-two).

The analog trip modules (ATMs) (or channels) used to provide the LOCA signal for automatic actuation of the containment spray system are the same ATMs (or channels) used to automatically initiate operation .

of the low pressure emergency core cooling systems (ECCS). In addition, the current Action Statements under Technical Specification 3/4.3.9 are based on the number of containment spray loops affected by inoperability of the instrument channels rather than the effect on the automatic actuation capability for the associated loop. In contrast, the Action Statements under Technical Specification 3/4.3.3 for the ECCS actuation function of these instruments are based on whether automatic trip capability has been affected for the associated ECCS loop. In order to maintain consistency with the proposed ECCS actuation function Action Statements (i.e., those contained in IP's September 20, 1991 amendment request) and to satisfy the preciously noted limitation of CENE-770-06-1 (regarding potential loss of function), IP now proposes to revise the Action Statements for the containment spray loops by deleting Action Statement "b" a d creating new Action Statements 52 and 53 for Table 3.3.9-1, " Plant Systems Actuation Instrumentation."

The proposed Action 52 is based on the number of channels that are affected (rather than the number of containment spray loops affected) so that the impact on automatic actuation capability for the associated containment spray loop is properly considered. Proposed Action 52 is consistent with the corresponding Action Statement for the i r/well Pressure-High and Reactor Vessel Water Level - Low Low Low, Level 1 instruments under Technical Specification 3/4.3.3. (See

, - . - - . - . - . - - - .- . . - - _ _ ~ . - . , - - - .

Attachment l

, to U-602025 LS-88-042 Page 5 of 7 Action 30.)- As the containment pressure signals for the containment

-spray system are arranged in a one out-of-two logic configuration, ,

inoperability of one containmene pressure instrument will not alone cause loss of the automatic actuation capability for the associated containment spray' loop. Therefore, proposed Action 52 has 4.n

. addition to-the Drywell Pressure - High and Reactor Vessel Water

. Level - Low Low Low, Level 1 Trip Functions) also been apolied to the Containment-Pressure - High Trip Function.

Proposed-Action 53 applies to those Trip Functions with od v one channel per containment spray loop. In the event that one o ~ these channels become inoperable, actuation of the associated contaiinent r spray loop could be prevented [ automatically (as in the case of timers) or manually (as in the case.of manual initiation pushbuttons)]-, As a result, it is appropriate to declare the associated containment spray loop inoperable and follow the appropriate Action Statement under Technical Specification 3/4.6.3.2,

" Containment Spray." Proposed Action 53 has accordingly been applied ,

to the Timers and Manual Initiation Trip Functions.

Proposed Actions 52 and 53 for the containment spray er.tuatior

-instrumentation are bounded by.the model Technical Specifications and analyses ptesented in GENE-770-06-1 (reference pages 15 and A-32) and appropriately implement the allowable repair A0T extension to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in only those instances where taking out the channel does not cause loss of the trip function.

Suppression Pool Makeup System The suppression pool mskeup system (SPMS) is described in CPS USAR Section 6.2.7. As stated in the USAR, the SPMS provides makeup water from the upper containment pool to the suppression pool by gravity

' flow following a LOCA. The quantity of water provided is sufficient l

to account for all conceivablo post-LOCA entrapment volumes to ensure that long-term drywell vent coverage is maintained. -The SPMS consists of two-independent lines, either of which is capable of providing the required water volume. Each of these lines contains g two normally-closed, motor-operated valves. .As these valves are I

arranged in series, opening of both valves is required to provide-

- -makeup water to the suppression pool via the associated dump line.

The-logic _for the SPMS is described in UShR Section 7.3.1.1.10.4 As.

described in the USAR, the SPMS can be actuated either: automatically or manually, provided the SPMS mode switch is in the " enable" position. {The SPMr rode switches are provided on a divisional basis to prevent.actuatim s abtomatically o. mar.ually) of that SPMS division (i.e.,-dwsr line). As described in USAR Section y 7.3.1.1.10.6, the SPMS is disabled during tuel handling activities to

prevent overexposure of refueling personnel as a result of an inadvertent SPMS actuation during--fuel handling activities.] With respect to automatic actuation of the SPMS, mach trip system-will automatically _open both. valves in the associatedadump line. Each trip system is-actuated with a LOCA signal (which is provided by two high drywell pressure and two low reactor water level, level 1 signals which are combined in a ane-out-of-two-twice logic-

Attachment 1 to U-602025 LS-88-042 Page 6 of 7 configuration) coincident with a low suppression pool level condition (two signals combined in a one-out-of-two logic arrangement).

Alternctely, the SPMS will automatically actuate approximately 30 minutes af ter a LOCA signal in the absence of a low suppression pool level condition. Further, each SPMS dwnp valve is equipped with a manual control switch. Manually opening both dump salves in a SPMS line will thus tesult in manual accustion of the associated $FM9 division.

Similar to the logic for the RHR containment spray system discussed above, the ATMs (or chsnnels) used to provide the LOCA signal for the SPMS are the same ATMs (or channels) used to initiate operation of the low pressure ECCS and RHR containment spray systems. The current _

Action Statement for these SPMS instruments (Action 50) is based on the number of trip systems affected by the inoperability rather than the impact on the automatic trip capability of that trip system.

Therefore, IP rroposes to revise Action 50 to address the number of channels that are affected (rather than the number of trip systems).

This proposed change will make Action 50 consistent with Action 52 for the RUR cantainment spray system and Activa 30 for the low pressure ECCS.

In addition, Action 50 currently allows placing the inoperable channel (s) and/or trip system in the tripped condition to satisfy the Action requirement. However, placing a trip syster in the tripped condition would result in actuation of the associated SPMS. As a result, IP proposes to delete this option from Actica 50. Further, as the low suppression pool water level signals are arranged in a one-out-of-two logic configuration (for each logic subsystem), .

inoperability of one suppression pool water level instrument will not al ane cause loss of automatic initiation capability for the associated SPMS line. Therefore, IP proposes that Action 50 also be _

applicable to the Suppression Pool Water Level-Low Low Trip Function.

The proposed chaages to Action 50 for the suppression pool makeup system actuatien instrumentation are bounded by the model Technical Specifications and analyses presented a GENE-770-06-1 (reference pages 16 and A-32-) and appro .iatelj implement the allowable repair AUT extension to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> on;y in those instances where takir; out the channel does not cause loss of the trip function. t Editorial / Format Channes In order to facilitate the use of a consistent format for the Action Statements for each of the plant systems actuation instruments, the current Action Statement "c" addressing the feedwater/ main-turbine trip system has been relocated to Table 3.3.9 1 as new Action 54. As there are no changes to these requirements, this change is purely edit rial.

Current Action Statement "d" addresses inoperability of SPMS actuation instrumentation and directs action to be taken as required by Table 3.3.9-1. As the action requirements for all instruments within the scope of this Technical Specification are now dictated by Tabic 3,3.9-1, Action Statement "d" has been replaced by new Action

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Attachment--1

- to U-602025 9;

LS-88 042-

. Page-7 of 7 Statement;"b" which generically. addresses inoperable plant systems actuation instrumentation. As the proposed Action "b" directs-action to be taken-as required by Table 3.3.9 1 for any inoperable-plant systems-actuation instrumentation and the applicable Action Statements are addressed above, this change does not resule in any technical changes. Therefore, this change is'also editorial.

' Footnote "*" to Table 3.3.9-1 currently states, in part that a ,

channel may be placed in-an inoperable status for required surveillans without placing the trip system in the tripped condition. Hosever, as stated above, placing a trip system in the

~ tripped condition will result-in-an automatic ectuation of the '

associated system (s). -In addition, each of the Action Statements (as proposed) only addresses placing a chu.nel in the tripped condition.

Therefore, IP-proposes to revise footnote "*" to state "...without placing the channel in the tripped condition...". As this more accurately-reflects _the proposed Action Statements, this propoaed

' change is also editorial.

-, . Finally, the word." action" has been replaced with the defined term-

'" ACTION" in the. proposed Action Statements to denote that-the associated Action Statement is being referenced. -Thcre is no change in intent, and.therefore, this change is also editorial.

Summary In summary, this submittalLprovides: (1) an additional reference for IP's

- proposed changes to-the RUIC actuation instrnmentation requirements as provided in I/*s September 20, 1991 amendment request, (2) makes editorial

- corrections to references for IP's proposed changes to the_ control rod block instrumentation:-requirements as provided in-IP's September 20, 1991

- amandment reque.t,.(3) provides a revision to the proposed rcpair AOT for

' the s in control room airLintake radiation'nenitors,'and (4)-provides

. reviatons = to othe Action Stacements (including format) and surveillance A0T

- footnote for-thefplant systems;ectuation' instrumentation. IP,has-reviewed-the(Bases for No-Significant Hazards Considerations provided IP's September-20,11991 amendment regunst and.has.cor.cluded that'the additional-changes contained in this revision do net. alter. the bases or conclusions provided

. in those assessments.

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