View source for JSP-613-92, Application for Amend to License NPF-62,changing TS 3/4.4.4, Chemistry to Add Requirement to Perform Evaluation Prior to Plant Restart of Impact on RCS of Chemistry Parameters Exceeding Limit During Plant Shutdown Conditions

{{Adams
| number = ML20126B052
| issue date = 12/15/1992
| title = Application for Amend to License NPF-62,changing TS 3/4.4.4, Chemistry to Add Requirement to Perform Evaluation Prior to Plant Restart of Impact on RCS of Chemistry Parameters Exceeding Limit During Plant Shutdown Conditions
| 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-613-92, U-602074, NUDOCS 9212210362
| package number = ML20126B055
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 6
| project = 
| stage = Request
}}

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Chrnon Powof t'aM P O Dox 070 CDnt a IL 61727 Te! 217 93&C??6 Fan 217 9% 4632
* J. Stephen Perry Sonor Vice P,euded ILLINOIS (12-15)-1P 8E100a JSP-613-92 December 15, 1992                            .,
10CFR50.90 Docket No. 50 461 Document Control Desk Nuclear Regulatory Conunission Washington, D1 0. 20555

==Subject:==
Clinton Power Station Proposed Amendment of Facility Operatinn License No. NPF-62

==Dear Sir:==

Purruant 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 a-proposed change to Technical Specification 3/4.4.4, " Chemistry". This proposed change will add a requirement to perform an evaluation prior to plant restart of the impact on the reactor coolant system of chemistry parameters exceeding their limit for specified time periods during plant shutdown conditions. This evaluation will ensure that the out of limit condition has not had an adverse impact on the reactor coolant pressure boundary.            In addition, this change will allow this Technical Specification to be met if the chemistry parameters have exceeded their limit for greater than the specified time periods.
A description of the proposed change and the associated justification (including the Basis For No Significant Hazards Consideration) are provided in Attachment 2. A marked up copy of the affected page from the current Technical Specifications 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 reviewod the proposed change against the criteria of 10CFR51.22 for categorical exclusion from environmental impact considerations. The proposed change does not involve a significant hazards consideration, or significantly increase the amounts or change the types of effluents that may be released'offsite, nor does it significantly increase individual or                  '
cumulative occupational radiation exposures. Based on the foregoing, IP concludes the proposed change meets the criteria given in 10CPR51,22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.
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Page 2 of 2 to U 602074 l
l CPS plans to perforrn chemical decontamination of portions of the Reactor Recirculation and Reactor Water Cleanup Systems during the fourth refueling outage (currently scheduled to begin September 26, 1993). Therefore, IP is requesting that the proposed changes be reviewed on a schedule suf ficient to support this outage.
Sincerely yours, Jf_.t.~ ) y ,
                                                    ~ .3 Per(y) z (JSenior
                                                    . S.Vice' President                                              -
ClJ /msh Attachrnents c(:    liRC Clinton Licensing Project Manager liRC Resident Office, V 690 Regional Administrator, Region 111. UStiRC Illinois Department of fluelear Safety l

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      ,                                                                                              Attachment 1
  ,                                                                                                  to U 602074 LS-92 017 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 Company; that the application for amendnent 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.
DATE:    This             i s'        day of December, 1992                                                       ,
                                                                                                 'a.
Signed:                         \             h bNY b,7 cJ.]Steph{nPerry                            O Subscribed and sworn to-before me this /g day of December 1992.
YlAs                      /b>fAh V/                               Notary Public
(:_ : ::::::::::::::::: -_-
4                  lbda S. French             l '
l;      Notary Public, State of IEnols        ll Q Wy comedision Empim S/1/96 f m.--       .,.m                      -       _ , _      . _ . . .                , . - .

Attachsant 2 to U 602074 Page 1 of 4 LS-92 017-Backcround As described in the Bases for Technical Specification 3.4.4, " Chemistry,"
water chemistry limits for the reactor coolant system are established to prevent damage to the reactor materials in contact with the coolant. Action statements are provided to ensure that appropriate actions are taken when a chemistry parameter exceeds the specified limit.      The actions prescribed by-the Standard Technical Specifications (See page 4 of this attachment) are defined according to the Operational Condition of the plant, Vhen the plant is in Operational Condition 1, the actions prescribed for out of specification conditions are dependent on the number / combination of parameters exconding the specified limits and on the period of tirne the chernistry limits are exceeded.
For Operational conditions 2 and 3, the prescribed actions for an out-of-specification condition are dependent on the period of time the specified limit is exceeded. For all other times (primarily shutdevn and offload conditions), if the conductivity, pH, or chloride concentration limits are exceeded, .a specified time limit for restoring each parameter to within ita=
limit is prescribed. In the Standard Technical Specification, if the time limit for any of the out of specification conditions is exceeded during plant l
shutdown conditions, an engineering evaluation is required to be performed to determine the effects of the out of-limit parameter.
During development of the draf t Technical Specifications for CPS, Technical Specification 3.4.4 was inadvertently formatted differently than the Standard Technical Specification. Specifically, Action Statements c.1.a and c.1.b were inconsistently formatted., resulting in the separation of the engineering evaluation requirement frorn the Action Statement addressing two of the chemistry parameters, conductivity and pH. The engineering evaluation was intended to be-the required action to be taken in response to any of the reactor water. chernistry parameters exceeding their limits for greater than 72 hours. This proposed change will thus correct the format of this Action Statement-to conform to the Standard Technical Specifications and allow this Technical Specification to be met when reactor water chemistry has exceeded one or more limits for greater than_72 hours.
l-          A chemical decontamination of. portions of the Reactor Recirculation and l           Reactor Water Cleanup Systems is scheduled to be performed during the next i           refueling outage. Should the decontarnination process result in a chemistry parameter _ exceeding the specified limit for more than 72 hours, the CPS Technical Specification could not be met as written. Therefore, approval of this Technical Specification change is needed prior to the. start of the refueling outage, which is currently scheduled to begin in September of 1993.
l-Descrintion of Pronosed Chance In accordance with 10CFR50.90, the following chanSes to Technical l_          Specification 3/4,4.4 " Chemistry," are being proposed:
           -1)     Delete the period at the end of Action Statement c.1.a and replace with
                   ", or".
ll
: 2)     Move to the left the portion of the paragraph at the end of Action Statement c.1.b that'begins " perform an engineering..." and align below parts "a" and "b" so both parts lead into this realigned paragraph, h

Attachment 2 to U.602074 Page 2 of 4 LS-92-017 This realigned section of text will require the performance of an engineering evaluation when any of the reactor water chemistry limits have been exceeded for greater than 72 hours when the plant is shut down.
Thase proposed changes are identified on the marked-up copy of the page from the current Technical Specifications contained in Attachment 3.
Justification for Proposed Chnnre As noted previously, t.ction c.1 of CPS Technical Specification 3.4.4 is formatted differently from the Standard Technical Specifications. The inconsistency between the CPS and Standard Technical Specifications inadvertently occurred during the development of the draft Technical Specifications for CPS. The enginecting evaluation requirement specified in the action statement was intended to apply to all three chemistry parameters when they have exceeded the required limits for more than 72 hours during shutdown conditions. The engineering evaluation must include the effects of the out-of-limit condition on the structural integrity of the reactor coolant system and determine whether it 1, acceptabic for continued operation prior to restarting the reactor. Under the current fo rrua t , the requirement to perform an engineering evaluation is only applicable when the chlorido concentration limit is exceeded during shutdown conditions.      As a result, if pH or conductivity is exceeded for more than 72 hours, this CPS Technical Specification cannot be met since no further action is specified.
The proposed change will merely bring the CPS Technical Specification into conformance with the Standard Technical Specifications and allow this Technical Specification to be met if pH or conductivity exceed the associated limit for greater than 72 hours.      This change does not involve any changes to the plant design and does not involve a significant change in the current operation of the plant and allow this Technical Specificatica to be met if pH or conductivity exceeds the associated limit for greater than 72 hours..                                  This change will ensure that the impact of the out-of-limit conditions on the reactor coolant system is determined prior to reactor startup.
Basis For No Significant 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 a new or different kind of accident from any accident previou ly evaluated, or (3) involve a significant reduction in a margin of safety. The requested change is evaluated against each of these criteria below.
(1)   The proposed change merely brings the current CPS Technical Specifications into conformance with the Standard Technical Specifications. This change would ensure that an engineering                             evaluation is completed to assess the effects of any chemistry parameter exceeding its limit for more than 72 houro. The engineering evaluation will supply the needed assessment of the impact of the out-of-limit condition on the reactor coolant system prior to reactor startup.                               In addition,

Attachment 2
        ,                                                                                                                                                                    to U 602074 Page 3 of 4 LS-92-017 these changes dc not affect any previous analyses.                                                                                                       Therefore, this request does not result in a significant increase in the probability or the consequences of any ac.ident previcusly evaluated.
(2)   The proposed change does not involve any changes to plant design nor does it involve a significant change in current plant operation.                                                                                                        No new failure modes are introduced as this change requires the performance of ar, engineering evaluation to determine the impact resulting from an out-v limit parameter prior to reactor startup. Therefore, the proposed change does not create the possibility of a new or different kind of recident from any accident previously evaluated.
(3)    The prop. ,ed change does not involve any changes to plant design nor does it involve a significant change in current plant operation. The proposed change does not involve changes to the currently specified chemistry linits nor to the specified time limits. The change to the Technical Specification would ensura that an engineering evaluation is                                                                                                        a completed to assess the out-of-limit parameter with respect *- the impact c, the structural integrity of the reactor coolant s' n 1 prior                                                                                                       p to reactor startup. With approval of the proposed change, i                                                                                                        acering   M l                   evaluation = will now be required where they previously were Therefore, this change does not involve a reduction in a marg.n of                                                                                                               '
safety.
J Based upon the foregoing. IP concludes that this request does not involve a significant hazards consideration.
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