View source for U-602075, Application for Amend to License NPF-62,changing TS 3/4.7.1.1, Shutdown Svc Water Sys (Loops A,B & C) & TS 3/4.7.2, CR Ventilation Sys, to Allow Tensioning & Detensioning Reactor Pressure Vessel Head

{{Adams
| number = ML20126A892
| issue date = 12/15/1992
| title = Application for Amend to License NPF-62,changing TS 3/4.7.1.1, Shutdown Svc Water Sys (Loops A,B & C) & TS 3/4.7.2, CR Ventilation Sys, to Allow Tensioning & Detensioning Reactor Pressure Vessel Head
| author name = Perry J
| author affiliation = ILLINOIS POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000461
| license number = 
| contact person = 
| document report number = JSP-615-92, U-602075, NUDOCS 9212210287
| package number = ML20126A894
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 8
| project = 
| stage = Request
}}

=Text=
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  ,                                                                              P.CL Box 670
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                    .                                                            Te; 217 335 6226
           .                                                                     FM 217 935 4632 J. Stephen Perry Senor Vice Pr Wdent ILLINISIS 1      9 (12-15)-LP 8E.100a Docket No. 50-461                                                      JSP-615-92 December 15,_1992-Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555

==Subject:==
Clinton Power Station Proposed Amendment of Facility
                             ,Qnertitine Licensa No. NPF 62                                                   -

==Dear Sir:==

Pursuant to 10CFRSO.90, Illinois Power (IP) hereby applies for amendment of Facility Operating License No. NPF-62, Appendix A - Technical Specifications, for Clinton Power Station (CPS).        This request consists of proposed changes to Technical Specifications 3/4.7.1.1, " Shutdown Service _
Water System (Loops A, B, C)," and 3/4.7.2, " Control Room Ventilation System."
These proposed changes would add exceptions to Technical Specification 3.0,4 to' allow tensioning and detensioning the reactor pressure vessel head with one                 '
of the required divisions of the systems addressed by these Technical Specifications inoperable. These proposed changes will-reduce the duration of an average refueling outage by approximately two days.
For each of these proposed Technical Specification changes,       a description, the associated justification (including a Basis For No                 __
Significant Hazards Consideration), and marked-up copies of pages from thu current Technical Specifications are provided_in Attachment 2. In addttion, an affidavit supporting the facts set forth in this letter and its attachments is provided in Attachment 1.
IP has reviewed the proposed changes against the criteria of-10CFRSI.22 for 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 occupational 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.
IP is requesting that these proposed _ changes be reviewed on a schedule sufficient to support the fourth refueling outage at CPS _ which is currently scheduled to begin on Sep_tember 26, 1993.                                                      -
Sincerely yours,
              $1.                                        I     7
: 4. S. Perry  _3' 9212210207 921215                               $*IfVIC*[,sident i
PDR
      -P ADOCK 05000461
_PDR
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DAS/ rash Attachments cc:                NRC Clinton Licensing Project Manager NRC Resident Office                                                                                                                                          j NRC Region III, Regional Adrainistrator Illinois Department of Nuclear Safety                                                                                                                       ;
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          ,                                                                                                                                      Attachinent 1                                                         !
to U-602075                                                          4 i
STATE OF ILLIN0IS COUNTY OF DEWITT J. Stephen Perry, being first duly sworn, deposes and says: That                                                                                                   l he is Senior Vice President of Illinois Power Cornpany; 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                                                                                                    l belief said application and the facts contained therein are true                                                                                                   ,
and correct.
DATED:        Thisif day of December 1992
* e              - 1 Signed:                      $N                 b        2. %           '
                                                                                                                                         .Stephenferry                                                                 "
Subscribed and sworn to before me this M day of December 1992,
                                                                                                                                                                                                                       +
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                                                                                                              "/                       Notary Public-
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                                                                                                                      -ll. My Commissisa Espiru 9/US$                       o V::::            ::_ :_           _ _ _ _ _ -w                                                :
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Attachrnent 2
          .                                                                   to U 602075
      ,                                                                       LS 92 015 Page 1 of 7 BACKCROUND Technical Specification (TS) 3.0.4 states that entry into an Operational Condition or other specified condition shall not be made unless the conditions for the Liiniting Condition for Operation (LCO) are inet without reliance on provisions contained in the Action requirements. Effectively, this TS prohibits a " mode" change frorn one plant operational mode to another mode or specified condition if entry into the new plant operating mode results in a condition not rsecting a particular LCO and thus requires operating under the Action Staternent for that LCO. A "3.0.4 exception" (i.e., a statement such as, "The provisions of Specification 3,0.4 are not applicable") allows entry into a particular Operational Condition when the plant is operating according to the provisions of an Action Statement that is applicable during the new Operational Condition. The Technical Specification changes proposed in this request would insert 3.0.4 exceptions into the Action Statements of Clinton Power Station (CPS) TS 3.7.1.1, " Shutdown Service Water System _(Loops A, B, c)," and 3.7.2, " Control Room Ventilation System." The requirements of these TS are briefly described below. Additional details and justification for the proposed changes to these TS are also provided below.
r;PS TS 3.7.1.1 currently requires Shutdown Service Water system (SX) loops to-be_ operable when systems or components which are cooled by the associated SX loop are required to be operable. If a requir9d SX loop is inoperable, the Action Statement requires those systems and components that rely en the inoperable SX loop for cooling to be declared-inoperable and the associated Action Statement (s) for those systems and components to be entered.
The Action Statement for TS 3.7.1,1 identifies the TS for only some of these affected systems or components. _ With an SX loop (s) declared inoperable, the remaining affected system or cornponents must be- declared inoperable and their respective TS Action Statements entered, as appropriate, notwithstanding the lack of specific references to their TS ,in the Action Statement of TS 3.7.1.1.
The syatems and cornponents having TS specifically . identified in the Action Statemor.t of TS 3.7.1.1 are as follows:       (1) the shutdown cooling mode of the Residual lleat Removal (RllR) system (3.4.9,1, " Residual lleat: Removal liot Shutdown;" 3.4.9.2, " Residual liest Removal Cold Shutdown; 3.9.11.1, " Residual l;          lleat Removal and Coolant Circulation liigh Water Level;" and 3.9.11.2,
             " Residual Heat Removal and Coolant Circulation-Low Water Level");- (2) emergency core cooling systems (ECCS) (3.5.1, "ECCS-Operating," and 3.5.2, "ECCS Shutdown"); and (3) AC Sources of the Electrical--Power Systems (3.8.1.1, "AC Sources-Operating," and 3.8.1.2, "AC Sources Shutdown") .
As noted above, the operability of other systems and components-may also potentially be impacted by inoperability of an SX loop.       Specifically, as a result of loss of cooling to the RHR _ heat exchangers, the containment spray mode of RilR (TS 3.6.3.2, " Containment Spray") and the suppression pool cooling mode of RHR (TS 3.6 3.3,." Suppression Pool Cooling") would be inoperable.
Additionally, as a result of loss of cooling to air handling unit cooling coils and safety-related chiller condensing coils,_the operability of the following systems would also.be potentially impacted: (1) raain stearn line isolation valve leakage control system'(MS1V LCS) (TS 3.6.1.4, "MS1V Leakage-i
        +       _____                                     _.

Attachusnt 2
                       ,                                                                                                            to U 602075
            .                                                                                                                       13 92 015
* Page 2 of 7                                           ,
Control System"); (2) standby gas treatment system (SCTS) (TS 3.6.6.3,
                           " Standby Gas Treatment System"); (3) containment hydrogen recombiners (TS 3.6.7.1, " Containment Hydrogen Recombiner Systems"); (4) containment andi drywell hydrogen mixing system (TS 3.6.7.2, " Containment /Drywell Hydrogen                                                                                    ;
Mixing System"); (5) main control room air conditioning filter train system                                                                                    '
(VC) (TS 3.7.2, " Control Room Ventilation System"); (6) Reactor Core Isolation Cooling (RCIC) system (TS 3.7.3, " Reactor Core Isolation Cooling                                                                                    ,
System"); (7) safety related battery DC power sources (TS 3.8.2.1, "DC                                                                                         ,
Sources operating," and TS 3.8.2.2, "DC Sources-Shutdown"); and (8) onsite                                                                                     '
power distribution systems (TS 3.8.3.1, " Distribution Operating," and TS 3.8.3.2, " Distribution Shutdown").
Many of the above-noted systems are only required to be operable while the plant is in Operational Condition 1, 2 or 3.                                    In addition, the Action Statement for TS 3.8.2.1 requires system restoration within two hours or the plant must be in Hot Shutdown within the next 12 hours and in Cold Ehutdown within the following 24 hours.                        These time limits are too short to allow preventive maintenance and testing of the Division 1 and Division 2 SX loops (loops A and B) during plant operation. As a result, routine preventive                                                                                       -
maintenance and testing of the Division 1 and Division 2 SX loops and their connected systems must be performed during plant shutdowns for refueling ~
outages.                                                                                                                                                       +
With respect to shutdown conditions, unless all of the fuel has been removed:
from the reactor vessel, a number of systems which are cooled by SX are still required to be operable. These include: -(1) the shutdown cooling mode of RHR (TS.3.4,9.1, 3.4.9.2, 3.9,11,1.and 3.9.11.2), (2) ECCS [TS 3.5.2-(unless                                                                                       '
reactor water 1cvel is greater than 23 feet above the reactor pressure vessel (RPV) flange)], (3) AC power sources-(TS 3.8.1.2), (4) DC power sources-(TS g                          3.8.2.2), (5) onsite electrical power distribution (TS.3.8.7.2), and (5) the main control room air conditioning / filter train system (TS7 3.7.2). ' In addition, redundant loops / subsystems of RHR shutdown cooling, ECCS, and main control room air conditioning (VC) are' required to'be orerable when the plant is in a shutdown condition. As a result,'both the Division I and II SX loops are required to be operable at all times unless all of the fuel-has been removed from the reactor vessel.
During routine preventive maintenance and-testing of an bX' loop during refueling outages the RHR shutdown cooling loop, ECCS, and main control room air conditioning subsystem. associated with a particular SX loop must be declared inoperable during the preventive maintenance or testing'of that-SX
                                                                                                                               ~
loop.        This, in turn, results in urnecessary restrictions on the refueling:
outage schedule by preventing removal and reinstallation of the RPV-head during this required preventive' maintenance'and testing. Critical path, time must be added to the ' refueling outage schedule to account for; the -requirement to delay the start of required activities on the-SX system until the RPV head-has been removed and to account for delaying RPV reassembly until required activities on the SX system have been completed. Illinois Power (IF)
                         - estimates that elimination of these restrictions.will result in an approximate
                         . two-day savings in the dura' tion of an average refueling outage.
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l Attachment 2                                     ;
            .                                                                                     to U.602075                                     i LS 92-015'                                       !
                       +-                                                                         Page 3 of 7 Description of Proposed Chance _pi In accordanco with 10CFR50.90, the following changes to the CPS TS are being proposed:
                                                                                                                                                -]
(1)      For TS 3.7.1.1, the Action Statement is being revised to add an exception to the provisions of TS 3.0.4 for entry into Operational Condition 4 or 5 when one required SX loop is inoperable,-and (2)      For TS 3.7.2   Action Statement b.1 is being revised to add an exception                                                j to the provisions of TS 3.0.4 for entry into Operational Condition 4 or                                                 i 5 when one main control room ventilation subsystem is inoperable.
It should be noted that the TS associated with RHR shutdown cooling loops (TS 3.4.9.2 and 3.9.11.2) currently contain exceptions to TS 3.0.4 for entry into Operational Conditions 4 and 5 with one (or both) RilR shutdown cooling mode                                                   -l loop (s) inoperabic. As a result, no further changes to these TS are required.                                                   '
The changes proposed in this request are reflected on the marked-up pages from the current CPS.TS are incidued as pages 6 and 7 of this attachment.
Juntification for Proposed Channes The proposed changes will only allow RPV head removal and installation with one required SX loop inoperable and will not alter the requirements to have all three SX loops operable prior to plant startup from the refueling outage.
With respect to the main control room air conditioning / filter train system, the proposed changes will continue to prevent the initiation of handling irradiated fuel in the secondary containment (Operational Condition "*") with                                                    '
one or more main control room ventilation systems inoperabic (since Operational Condition "*" was not included in the proposed exception to TS 3,0.4).      In addition, the CPS TS will continue to prevent removal or installation of the RPV head with an inoperable SX loop associated with a diesel generator, safety related battery, or electrical-power distribution system required operable, since TS 3.8.1.2, 3.8.2.2, and 3,8,3.2 do not include exceptions to TS 3.0.4. Consequently, at 1 cast one operable main control room ventilation train supported by an operable SX system and an operable. diesel generator will continue to be required while the RPV head is being removed or installed.
The primary design basis accident. analyses (Updated Safety Analysis Report (USAR) Chapter 15] which are applicable to plant shutdown conditions (Operational Condition 4 and 5) are those addressing fuel handling accidents (USAR Section 15,7.4) and inadvertent criticality (USAR Section 15,4.1.1).
The proposed-changes .do not affect the probability of occurrence of- these events because their prevention is ensured by other requirements, design features, and controls, such as the one rod-out interlock,; shutdown margin requirements, crane physical ~ stops,.etc. In addition, removal or.                                                              '
reinstallation of the RPV head has no cifect on decay heat generation-or removal. As a result, these proposed changes maintain an equivalent level of '
safety during removal or installation of the PPV head.                       Further, these
              . proposed changes are consistent with-the allowances for plant mode changes-provided in NRC Generic Letter 87-09=[and the new Improved Technical Specifications (NUREG-1434)].
                                                                                                                                               .i
  < + , - - .        _       _ -  . . .     .-   . --  . - - . . . . - - - -.a _ - . - - - _ _ .         - - . - _ _ _ _ . _ _ _ _ _ _ . . - .

Attachment 2 to U 602075 LS 92 015 Page 4 of 7 lu s i s Fo r !!1L S_Lr,n i f i c ent H a r a rd s Cop s i de r a t i o n in accordance with 10CTR50.92, a proposed change to the operating license or Technical Specificationn 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, (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. The proposed changes are evaluated against each of these criteria below.
(1)       The probability of occurrence of postulated accidents associated with plant shutdown conditions (inadvertent criticality and fuel handling accidents) is not increased by the proposed changes since those accidents are prevented or mitigated by other controls, design features,                                                                                         -
and requirements, such as the one rod-out interlock, shutdown margin, crano physical stops, etc.                 Further, the applicable mode changes (RPV head removal / installation) do not affect the probability of occurrence of such accidents. Since the proposed changes will still require one SX loop associated with an operable diesel generator, DC power source, cicetrical power distribution system, and main control room ventilation system to be operable during the applicable mode changes, these proposed changes will not increase the consequences of any accident previously evaluated. Therefore, the proposed changes do not involve a significant increase in the probability or the consequences of any accident previously evaluated.
(?)      The proposed changes do not involve any changes to plant design nor do they involve a significant change in plant operation from what is currently allowed by the CPS Technical Specifications. The impact of the proposed changes is limited to the potential effect on main control room air conditioning system availability and core decay heat removal during removal or installation of the RPV head. At least one main control room air conditioning subsystem associated with an operable SX                                                                                            -
loop must continue to be operable and two PJIR uhutdown cooling mode loops (or their alternates) must also be operable while removing or installing the RPV head.                Therefore, IP believes that the proposed changes do not involve a significant change to the requirements for these safety functions during those conditions. Based on the above, the proposed changes do not create the possibility of a new or difforent kind of accident from any accident previously evaluated.
: 3)        As noted above, at least one main control room air conditioning subsystem associated with an operablo SX loop must continue to be operable and two RilR shutdown cooling mode loops (or their alternates) must also be operable while removing or installing the RPV                                                                                       head. As a result, the proposed changes do not involve a significant                                                                                      reduction in core decay heat removal capability or protection for main                                                                                      control room personnel during the period of time the RPV head is being                                                                                      removed or i
                                                                                - - - . - - - - - _ . - . - - - - - - - _ . - - - - - - - - , , - - - - - _                    .A

Attachment 2 l
        ,                                                                                              to U 602075 LS-92 015
               -                                                                                       Page 5 of 7 I                installed.                             Therefore, the proposed changes do not involve a significant j                reduction in a margin of safety assumed or required in any accident or transient analysis.
Based on the foregoing, IP has concluded that these proposed changes do not involve a significant hazards consideration.
(TBE5/DAS6)
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