JSP-528-92, Application for Amend to License NPF-62,consisting of Proposed Editorial Changes to OL & TS to Correct Typos, Provide Clarification & Remove Provisions No Longer Applicable

Application for Amend to License NPF-62,consisting of Proposed Editorial Changes to OL & TS to Correct Typos, Provide Clarification & Remove Provisions No Longer Applicable

ML20115G104
Person / Time
Site:	Clinton
Issue date:	10/16/1992
From:	Jamila Perry ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20115G107	List: JSP-528-92, Application for Amend to License NPF-62,consisting of Proposed Editorial Changes to OL & TS to Correct Typos, Provide Clarification & Remove Provisions No Longer Applicable ML20115G118
References
JSP-0528-92, JSP-528-92, U-602041, NUDOCS 9210260023
Download: ML20115G104 (6)

Text

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_. \f e Illnois Power ( mpany o

I C:nton Power btstico

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• P O- Bca 678 Canta IL 61727

' Tel' 217 946226  ;

, Fax 217 954632 -l J. Stephen Perry Senor Vice Prep:!ent ILLIN9IS POWER u.6 2041 L47 92 (10-16)LP 8E.100a 10CFR50.90 ,

Docket No. 50 461 JSP-0528-92 October 16, 1992 Document Control Desk Nuclear Regulatory Commission Washington,'D.C, 20555

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Subject:

Clinton Power Station Proposed Amendment of Facility Operatinr. L> cense No, NPF-62

Dear Sir:

Pursuant to 10CFR50.90, Illinois Power (IP) hereby applies for amendment of Facility Operating License No. NPF 62 and Appendix A to the Operating License (Tochnical Specifications), for Clinton Power Station (CPS). This request consists of proposed editorial changes to the CPS Operating License and Technical Specifications to correct typographical errors, provide clarification and remove provisions which are no longer applicable. A description of the proposed changes, the associated justifications (including a basis for No Significant Hazards Consideration), and a marked up copy of the affected pages of tae current Operating License and Technical Specifications are ,,rovided in Attachment 2. In addition, an affidavit supporting the facts set forth in this letter and its attachment is provided in Attschment 1.

IP has reviewed the proposed change against the criteria of 10CFR51.22Tfor

. categorical exclusion from environmental. impact 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 occupacional radiation:

exposures. - Based on the foregoing, IP concludes the proposed changes meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the-requirement:.

for an Environmental Impact Statement, Sincerely yours, (ScPerr*

.. enior Vice President h TAB / ash p .Attachmente n

[ ;cc: NRC Clinton Licensing Project Manager l NRC Resident Office-, V-690

l. Regional Administrator,-Region III, USNRC Illinois Department of Nuclear Safety t

• 9210260023 921016 2

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

That he is Senior Vice President of Illinois Power Conpany;-

that the application for amendment of Facility Operating License NPF-62 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 application and the facts contained therein are true and correct.

t DATE: This 1 day of.0ctober 1992 Signed .

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. (tjephen Perry Q Subscribed-andsworntobeforemethis[ day' of October 1992.

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Attacheent 2

. to U 602041 LS92-013 Page 1 of 13 RenrirMen of pronosed Chanc.g In accordance with 10CFR50.90, the following editorial changes to the CPS Operating License and Technical Specifications are being proposed:  ;

I

1. Delete item (b) from paragraph D of the CPS Operating License ar.d relotter the remaining items, as appropriate. Item (b) provided exemptions from the requirements of General Design Criteria (CDC) 61 to permit the deferral of a portion of the Fuel llandling System preoperational testing until prior to off loading fuel from the reactor vessel. Since the testing has been completed and the system declared operable, this license condition is being deleted ftom the Operating License.

2. Revise Technical specification 3.5.2, "ECCS- Shutdown," item e.2 and Technical Specification 3.5.3, " Suppression Pool," item b.3 to delete j the condition " equivalent to a level of 954". Technical Specifications  !

3.5.2.c.2 and 3.5.3.b.3 identify the minimum required available volume in the Reactor Core Isolation Cooling (RCIC) System storage tank in the event the suppression pool level is less than the applicable limit during operational conditions 4 and 5*. The Technical Specifications currently identify an available volume of at least 125,000 gallons of water, equivalent to a level of 954 Since the available level instrumentation does not provide icvel indication in terms of percentage, this condition la being deleted from the referenced Technical Specifications.

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3. Revise Technical Specification 3.8.3.2, " Distribution Shutdown," item a.3.d to delete the "*" attached to this item. Technical Specification Limiting Condition For Operation (LCO) 3.8.3.2.a.3 identifies the Division 111 AC power distribution system equipment required to be ,

operable during shutdown conditions. Footnote "**, which states "When handling irradiated fuel in the secondary containment," was intended to define the "*" which appears in the LCO Applicability statement. While Technical Specification 3.8.3.2.a.3.d is applicable during the operational condition defined by "*", it was not intended that-the "*"

be attached to item a.3.d. Therefore, the "*" is b-ing deleted from Technical Specification 3.8.3.2.a.3.d.

4. Revise Technical Specification 3/4.9.12, " Inclined Fuel Transfer System," to delete footnote ***". Delayed preoperational tescing of the Fuel llandling System resulted in the addition of footnote "**" to Technical specification 3/4.9.12 to permit an exception to the operability requirements for the blocking ,1ve in the fuel building Inclined Puel Transfer System hydraulic pc4e unit and the liquid level indicator prior to off-loading irradiated fuel-from the reactor vessel.

Since the testing has been completed and the system was declared +

operable, the footnate is no longer needed and is thus being deleted from the referenced Technical Specification, ,

5. Revise Technical Specification 6.12.3 to indicate applicability of.

footnoto "*** vice footnote "*". Technical Specification 6.12 L

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. Attachment 2 to U-002041 y 1.S-92-013 Page 2 of 13 identifies requirements for control of high radf - or, areas. otnote

"*" was inadvettently identified as applicable .o ?echnical

~

ocification 6.'7.') (controls for entry into at m accessible to

,ionm l such t w the measured dose rate i,. in excess of 3000 r,tr) when it was intendert that footnote "**" be apt..ic.;,ble to this ation. Therefore, Technical Specificaticn 6.12.3 will be

- to indicate the applicability of footnote "**".

< Lpii for Provnsed Chanee

- T; . w ,cd changes do not alter any of the requirements or technical baces j provb..

• uha CPS Operating License and Technical Specifications. All required a rions remain unchan pd wi the proposed revisions delete provisions which ute n; longer applicable, provide clarification and correct previously q

'p, id(.tified typographical errors. Consequently, these changes are editorial only. Tha justification for eacia proposed change is provided below. [_ _

At the time of in;tial fuel loading at CPS, it +2s not possible to cora91 ete the preoperational testing of the Fue 7dling (ni) Syro.4 elated to the 5 t .ar,sfer of fuel bundles under wet los g conditi & s. A s. t result, IP A '

requested an exemption to 10CFR50, Apr .lix A, CDC (h te pet;'.t the deferral of the preopecational testing of the Mi systeri under wet ~ 4a' ag conditions until prior to of f-:- i. - irradiated fuel. This exempt b.i, as documented in CPS Safety Evalua y,s t Supplement 8, was included in the full-power Operativt icense tw . . '3 . In addition, footnote **" was added to Technical Specifiw can 3/4.9.12 to indicate that operability of portions of the ni f/

system would not be required uutti completion of the preoperational testing (which would be required to on performed prior to off-loading trradiated fuel from the rea tor vessel). Subsequent to NRC approval of the exemption, IP comphted the testing of the R1 system and the system was then declared oper M e. Completion of this testing was documcated in NRC Inspection Report 50-461/87039 dated January 24, 1% 8. Therefore, the footnote in Technical Specification 3/4.9.12 is no longer applicable, and the exemption in para 5raph D is no longer needed. The footnote and exemption can thus be de'eted. These _

changes do not delete any requiremeats, and in fact, make the Operating g License and Technical Specifications consistent with the current plant star 2.

During a CPS-taltiated safety system functional inspection, I? discovered that the control roon surveillance log and the applicable Technical Specification indicate the R',1C system atonage tank level should be maintained at a level

" equivalent to 95%". The Icg and Technical Specification do not indicate if

.; this 't available volume or total volume and the percentage is not easily correlated with the tank level range of 0-30 feet as inoicated on the installed levet instrumentation. The purpose of the Technical Specification is to require a minimum avriilable water volume of 125,000 gallons as specified, Therefore, since the statement " equivalent to 95%" does not provide the operator.with any useful additional information and has been a point of confusion to the operators, it is proposed that the statement related to equivalency be deleted from the Technical Specifications. Th'.o change does not i!= pact tha requirement for che minimum available volume of cr in the tank. 'Ihe operators are provided with an aid te equate tank levo co tank volume which eliminates confusion and ensures compliance with sy. o requiremerts W Nut the noced, confusing statement.

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1 Attachmsnt 2-

. . to U-602041-LS-92-013 Page 3 of-13 Technical Specification LCO 3.8.3.2.a.3 identifies the Division Ill AC power distribution system equipment required to be operable during shutdown conditions. Footnote "*", which r;ates "When handling irradiated fuel in the secondary containment", is provided to define the "*" which appears in the LCO Applicability statement. The "*" was inadvertently attached to LCO .i 3.8.3.2.a.3.d. Therefore, the **" is inappropriate and is being deleted from 140 3.8.3.2.a.3.d. This change will not impact which equipment is required to be operable, but will eliminate confusion generated by the "*" inappropriately being attached to the LCO.

Technical pecification 6.12 identifies the requirements for control of high radiation areas, and Technical Specificasion 6.12.3 provides. specific controls for entry into areas accessible to personnel such that the measured dose rate is in excess of 3000 mrem / hour. Footnote "**" is provided to indicate at what distance frcm the source the dose rate is to be measured. However, footnote

"*" , which provides exceptions to the use of a radiation vork permit,.vas-Inadverter.tly identified as applicable to Specification 6.12.3. Therefore,-to provide clarification and ensure consistency between Technical Specificationa 6.12.1, 6.12.2 and 6.12.3, footnote "*" in Specification 6.12.3 is being replaced with footnote "**". This change does not impact IP's compliance with the requirements of 10CFR20, nor does it alter any of IP's requirements or responsibilities for protection of the public and employees against "adiation hazards.

Basis for No Sinnificant Hazards Consideration In accordance with-10CFR50.92, a proposed change to the Operating 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 any accident previously evaluated, or (2) create the possibility of t- new ci different kind of accident from any accident previously evaluated, or -(3) l involve .i significant reduction in a margin of safety. The proposed changer I

are collectively evaluated against each of these criteria as follows: .

(1) The proposed changes only consist of clarifications, corrections of typographical errors and .the deletion of provisions which are no longer applicable. Therefore, these~ changes do not affect at3 previous analysis. These changes do not affect tiu intent or la;4ementation of the applicable Technical Specifications, and in fact. reduce or eliminate confusion,-provide consistency between Technical Specifications,-an1 ensure that the Operating License and Technical Spr41fications reficct current plant status'. Since'these'are editorial changes which do not inpact the plant design or operations,.this proposed change cannot increase the probability or the consequences of.

.any accident previously evaluatet (2) The proposed changes are editorial only and do not affect the plant design or operation. No new fe.ilure' modes are introduced since these proposed changes only correct typographical errors suui provide additional clarificatian. Therefore, the request will not' create.the possibility of a new or Gifferent kind of accident from any accident previoucly evaluated.

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(3) The proposed changes only provide correction of typographical errors and clarification of inconsistent direction to the operators. These changer, do not alter or delete technical requi*ements and as such, maintain an eqaivalent level of safety. Therefot ,

these chan6es do not involve- a reduction in a margin'or safety -

l Based upon the 'foregsing, IP concludes that the. n changes - Tot. involve--a- I sigrificant hazard consideration.  !

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