U-602364, Application for Amend to License NPF-62,providing Final Rev to TS by Converting to Improved TS Per NUREG-1434, Improved BWR-6 TS, Rev 0,dated Sept 1992

Application for Amend to License NPF-62,providing Final Rev to TS by Converting to Improved TS Per NUREG-1434, Improved BWR-6 TS, Rev 0,dated Sept 1992

ML20078D880
Person / Time
Site:	Clinton
Issue date:	10/31/1994
From:	Jackie Cook ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20078D882	List: U-602364, Application for Amend to License NPF-62,providing Final Rev to TS by Converting to Improved TS Per NUREG-1434, Improved BWR-6 TS, Rev 0,dated Sept 1992
References
RTR-NUREG-1434 U-602364, NUDOCS 9411080269
Download: ML20078D880 (15)

Text

'

lihnois Power Cornpany Chnton Power Stabon is P O Box 678 Chnton, IL 61727 c.

Tel 217 935-5623 k

Fax 217 93r 1632 John G. Cook ILLIN9BS

'"l*0$*6!

u PGMR uv-94(to - 313te c

8E.100a JGC-326-94 October 31, 1994 Docket No. 50-461 10CFR50.90 Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Clinton Power Station Final Revision to Previously Submitted Proposed Amendment of Facility Operating License No. NPF-62 (

References:

IP Letters U-602196 dated October 26.1993 and U-602283 dated April 26.1994)

Dear Sir:

l By letter dated October 26,1993 (reference letter U-602196), Illinois Power (IP) applied fet amendment ofFacility Openting License No. NPF-62, Appendix A -

T4chnical Specifications for Clinton Power Station (CPS). By that application, IP requested a complete revision of the CPS Technical Specifications to convert to the Improved Technical Specificaticns (ITS) per the guidance provided by NUREG-1434,

" Improved BWR-6 Technical Specifications," Revision 0, dated September 1992.

Enclosun 2 ofIP's October 26,1993 submittal was organized by Technical Specification section (including the associated Bases section). For each section within Enclosure 2 of IP's October 26,1993 submittal, IP provided markups of the current C.PS Technical Specifications (includingjustifications and No Significant Hazards Consideration evaluations for each of the changes from the current CPS Technical Specifications) and markups of the associated NUREG-1434 Technical Specifications (includingjustifications for deviations).

Subsequent to IP's October 26,1993 submittal, and as a result of additional guidance provided by the NRC staff for improving the scope and content of the Administrative Controls section of the Technical Specifications, additional proposed changes were submitted to the NRC staff by followup IP letter U-602283 dated April 26, 1994. The changes were provided in the form of replacement pages to replace the corresponding pages in Enclosure 2 ofIP's October 26,1993 submittal.

Earlier this year, in accordance with a pre-arranged program to generically review

- the application of NUREG-1434 to the BWR-6 plants, the NRC staff begar,its review of IP's ITS submittal along with the ITS submittals for the other three BWR-6 plants.

3Di '

M nseE Shi P

U-602364 Page 2 Representatives from the BWR-6 plants met regularly with the NRC staff to resolve comments, issues, and open items identified in the course of the staffs review. The staffs BWR-6 review is now essentially complete, and all open items related to the CPS-specific review have been resolved. Resolution of the comments, issues, and open items stemming from the NRC staffs review requires changes to be made to IP's ITS submittal. By this letter, those changes are thus requested. The changes are reflected in Enclosure 4 to this letter, and similar to IP's April 26,1994 letter, the changes are provided in the form of replacement pages for the corresponding pages provided in Enclosure 2 ofIP's October 26,1993 submittal. Due to the large scope of changes, the changes / replacement pages provided in Enclosure 4 of this letter are organized by Technical Specification section, similar to the October 26,1993 submittal.

Other information required to support CPS's conversion to the Improved Technical Specifications is provided in additional Enclosures to this letter. For assuring that requirements which are to be relocated from the Technical Specifications will continue to be adequately controlled (i.e., properly maintained and/or reviewed when changes to those requirements are proposed), a matrix is provided as Enclosure 2 to this letter. The matrix identifies each relocated Technical Specification (by its current number), the corresponding new location (e.g., the Updated Safety Analysis Report), and the applicable regulation or requirement (e.g.,10 CFR50.71(e)] that provides controls on future changes to these requirements. Enclosure 3 is a matrix which provides an assessment of the impact of new ITS Technical Specification 3.0.4 on each Technical Specification (Limiting Condition for Operation) with respect to whether or how mode changes are permitted while operating under the provisions of the associated Action statement, particularly during shutdown conditions. This matrix was requested as part of the resolution of generic changes to the ITS Technical Specification 3.0.4. Enclosure 5 is a complete, typed copy of the new Technical Specifications for CPS, including the Table of Contents, and Enclosure 6 is a complete, typed copy of the associated Bases. Enclosures 5 and 6 reflect incorporation of all the changes requested by IP in its October 26,1993 and April 26,1994 applications, as modified by the changes indicated in Enclosure 4 to this letter. Finally, an affidavit supporting the facts stated in this letter and its enclosures is provided as Enclosure 1 to this letter.

IP has reviewed the proposed changes against the criteria of 10CFR51.22 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 enluents that rmy be released oft-sne, nor do they significantly increase individual or u.mu!ne 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.

U-602364 Page 3 This request has been reviewed by the CPS Facility Review Group (FRG).

t Sincerely yours,

. G. Cook Vice President TBE/csm cc:

NRC Clinton Licensing Project Manager NRC Resident Oftice, V-690 Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety l

1 1

i 1

~.

to U-602364 STATE OF ILLINOIS

- COUNTY OF DEWITT L

John G. Cook, being first duly sworn, deposes and says: That he is Vice President of Illinois Power Company; 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 letter and the facts contained therein are true and correct.

This N5* day of October 1994.

Date:

Signed:

\\

t STATE OF ILLINOIS l SS.

• hyh f

NotryPutsc,Stahof Annis Jewiw COUNTY j

f WCommissbnExpiresit/2M7 j w...

Subscribed and sworn to before me this 314+ day of October 1994.

h b.

(Notary Public) l l

t to U-602364 P,

PageIof4

SUMMARY

OF CLINTON POWER STATION RELOCATED TECHNICAL SPECIFICATIONS EXISTING TS TITLE RELOCATION CONTROLS 4.0.5 Inservice Inspection and Testing 10 CFR Programs 50.55a/ORM 3/4.1.3.6 Control Rod Drive Housing ORM Support 3/4.3.1.1.7 MSL Radiation - High Scram ORM 3/4.3.2.1.1 MSL Radiation - High MSL and ORM 3/4.3.2.2.b CRVICS Isolation Functions 3/4.3.2.2.g Area Differential Temperature ORM 3/4.3.2.3.d High Isolation Functions for 3/4.3.2.3.g MSL, Reactor Water Cleanup, 3/4.3.2.4.f RCIC, and RHR systems.

3/4.3.2.4.h 3/4.3.2.4.n 3/4.3.2.5.b 3/4.3.3.A.2.h ADS Manual Inhibit Functions ITS 3.3.5.1 3/4.3.3.B.2.h BASES /USAR 7.3-9 3/4.3.6.2 Control Rod Block ORM 3/4.3.6.3 Instrumentation for APRM, SRM, 3/4.3.6.4 IRM, Scram Discharge Volume, and 3/4.3.6.5 Reactor Coolant System 3/4.3.6.6 Recirculation Flow Functions.

3/4.3.7.1.2 Area Radiation Monitors ORM 3/4.3.7.2 Seismic Monitoring ORM Instrumentation 3/4.3.7.3 Meteorological Monitoring ORM Instrumentation 3/4.3.7.7 Traversing In-Core Probe System ORM 3/4.3.7.8 Chlorine Detection System In accordance with Footnote #,

this TS is no longer applicable.

1 3/4.3.7.10 Loose-Part Detection System ORM 1

Ecciosure 2 to UA Page 2 of =.

SUMMARY

OF CLINTON POWER STATION RELOCATED TECHNICAL SPECIFICATIONS (continued)

EXISTING TS TITLE RELOCATION CONTROLS 3/4.3.7.11 Main Condenser Offgas Treatment ORM System Explosive Gas Monitoring Instrumentation 3/4.3.9.2 Feedwater/ Main Turbine Trip ORM System 3/4.3.9.3.f Suppression Pool Makeup Mode ITS 3.6.2.4 Switch Permissive Function BASES 3/4.3.10 Nuclear System Protection System ORM

- Self Test System 3/4.4.4 Reactor Coolant System Chemistry ORM 3/4.4.8 Reactor Coolant System ORM Structural Integrity 3/4.7.4 Snubbers ORM 3/4.7.5 Sealed Source Contamination ORM.

3/4.8.4.1 Containment Penetration ORM Conductor Overcurrent Protective Devices j

3/4.8.4.2 Motor Operated Valves Thermal ORM Overload Protection 1

3/4.9.4 Refueling Operations Decay Time ORM j

3/4.9.5 Refueling Operations ORM Communications 3/4.9.6.1 Refueling Operations Fuel ORM 3/4.9.6.2 Handling Equipment Refueling Platform and Auxiliary Platform 3/4.9.7 Refueling Operations Crane ORM Travel - Spent Fuel Storage Pool, Upper Containment Fuel Pool, and New Fuel Storage Vault 3/4.9.12 Refueling Operations Inclined ORM Fuel Transfer System 5.2 Containment Design Features USAR 6.2 2

to U-602364 hge 3 of 4

SUMMARY

OF CLINTON POWER STATION i

RELOCATED TECHNICAL SPECIFICATIONS (continued) 1 I

EXISTING TS TITLE RELOCATION CONTROLS 5.4 Reactor Coolant System Design USAR Table Features 5.4-1, Figure 5.1-2 5.5 Meteorological Tower Location USAR Figure Design Features 2.3-18 6.1.2 Control Room Command Management ORM Directive 6.2.2.a Minimum Shift Composition 10 CFR Table 6.2.2-1 Minimum Shift Composition

50. 54 (m) /ORM 6.2.2.d SRO Present During Fuel Handling 6.2.2.e Fire Brigade Composition ORM/ License Condition 2.F 6.2.2.f Nominal Work Week ORM 6.2.3 ISEG ORM 6.4 Training ORM/10CFR55 6.5 Review and Audits ORM/10 CFR 50.54 6.6 Reportable Event Action 10 CFR 50.73/ORM 6.7 Safety Limit Violation 10 CFR 50.72/50.73/

ORM 6.8.1.e Security Plan Implementation 10 CFR 6.8.1.f Emergency Plan Implementation 50.54/ORM 6.8.1.g Fire Protection Program ORM/ License 6.8.4.e Implementation Condition 2.F 6.8.2 Review and Approval 10 CFR 6.8.3 Temporary Changes 50.54/ORM 6.8.4.b In-Plant Radiation Monitoring ORM 6.8.4.g Radiological Environmental ODCM/ORM Monitoring Programs 3

. to U-602364 t

Page 4 o(4 L

SUMMARY

OF CLINTON POWER STATION RELOCATED TECHNICAL SPECIFICATIONS (continued)

EXISTING TS TITLE RELOCATION CONTROLS 6.9.1 Startup Report ORM 6.9.1.5.c Specific Activity Annual Report 10 CFR 50.72/50.73 6.9.2 Special Reports:

( 3 /4. 5.1 (ECCS Actuation Special Report) 10 CFR Action g) 50.72/50.73 (4. 8.1.1. 3 )

(DG Failure Special Report) 10 CFR 50.72/50.73 (3/4.3.7.5 (PAM Inoperability Special ITS 3.3.3.1 Action 81.b)

Report)

Bases 6.10 Record Retention 10CFR50.54/

10CFR20/

10'jR71/ORM 6.11 Radiation Protection Program 10CFR20/ORM 6.13 Process Control Program 10CFR20/

10CFR61/

10CFR71/ORM ORM =

Operational Requirements Manual controlled by 10 CFR 50.59.

ODCM =

Controlled by Technical Specification 5.5.1.

USAR =

Updated Safety Analysis Report controlled by 10 CFR

50. 71 (e).

ITS Bases =

Controlled by Technical Specification 5.5.11.

4

tactosure 3 to U-602364 PageI or7 Clinton Power Station October 29. 1994 LC0 3.0.4 EVALUATION Pg 1 LC0 -

New Applbty Comments / Justification Allow Xfer (Refer to Page 7) 3.1.1 SDM n

All others (See assumption 2.)

n M4 from M3, (See Note A.)

M4 from M5, M5 from M4

]

M5 from M6 (See assumption 3.)

i 3.1.2 Rx Anomoly n

M2 from M1 (See assumption 2.)

3.1.3 CRod OPER n

M2 from M1 (See Note A and assumption 2.)

3.1.4 CRod Scram Tm n

M2 from M1 (See assumption 2.)

3.1.5 CRod Accum n

M2 from M1 (See Note A and assumption 2.)

3.1.6 CRod Pattern n

to 520% RTP (See Note A for 5 8 rods not in compliance.)

(See Assumption 2 for > 9 rods.)

3.1.7 SLC System n

M2 from M1 (See assumption 2.)

3.1.8 SDV Vent /Drn n

M2 from M1 (See assumption 2.)

[

3.2.1 APLHGR n

NA No way to enter applicability except on startup l

3.2.2 MCPR n

NA No way to enter applicability except on startup 3.2.3 LHGR n

NA No way to enter applicability except on startup 3.3.1.1 RP5 y

M2 from M1 For IRMs & APRM-Setdown:

See Notes A and B.

n All others (See Note A and assumption 2.)

3.3.1.2 SRM y

to IRM 5R2 See Note B n

M3 from M2, (See Note A)

M3 from M4 M4 from M3, M4 from M5.

M5 from M4 n

M5 from M6 (See assumption 3.)

3.3.2.1 CRod Block n

ALL (See Note A.)

q 3.3.3.1 Post Acc Mn n

ALL Existing 3.0.4 exception 3.3.3.2 Remote SD n

ALL Existing 3.0.4 exception 3.3.4.1 EOC-RPT n

ALL No way to enter applicability except on startup 3.3.4.2 ATWS-RPT n

ALL Ne g y to enter applicability except on startup

'te A.)

3.3.5.1 ECCS Instr n

ALL 3.3.5.2 RCIC Instr n

ALL (See Note A.)

3.3.6.1 PCI Instr n

ALL (See Note A and assumption 2.)

-.. - = -.

~ to U402364 Page 2 of 7 Clinton Power Station October 29. 1994 LCO 3.0.4 EVALUATION Pg 2 LCO New Applbty-Comments / Justification Allow Xfer (Refer to Page 7) 3.3.6.2 SCI Instr n

ALL (See Note A.)

3.3.6.3 RHR Cont.

n ALL (See Note A.)

Spray Instr.

3.3.6.4 SPMU Instr n

ALL (See Note A.)

3.3.6.5 LLS Instr n

ALL (See Note A and assumption 2.)

3.3.7.1 CRV Instr n

ALL (See Note A.)

3.3.8.1 LOP Instr n

.ALL (See Note A.)

3.3.8.2 RPS EPAs n

M2 from M1.

(See assumption 2.)

M3 from M2, M4 from M3 n

M4 from MS.

(See Note A and assumption 3.)

M5 from M4 n

M5 from M6 (See Note A.)

i 3.4.1 Recirc Opertn n

M2 from M1 (See Note A and assumption 2.)

3.4.2 Flow CVs n

ALL (See Note A and assumption 2) 3.4.3 Jet Pumps n

M2 from M1 (See assumption 2.)

3.4.4 SRVs n

M2 from M1 (See assumption 2.)

M3 from M2 3.4.5 Rx Leakage n

M2 from M1 (See assumption 2.)

M3 from M2 3.4.6 PIVs n

M2 from M1 (See Note A and assumption 2.)

M3 from M2 3.4.7 Leak Det Inst n

M2 from M1 Existing exceptions to 3.0.4, see Note A and M3 from M2 assumption 2.

3.4.8 Specf Actvty n

M2 from M1 (See assumption 2.) Also, existing exception to M3 from M2 3.0.4.

3.4.9 RHR-SDC

Hot n

ALL Existing exception to 3.0.4 3.4.10 RHR-SDC: Cold n

M4 from M3 Would be MODE change required by ACTIONS of LC0 3.4.9.

ri M4 from M5 (See Note A.)

3.4.11 PT Limits n

NA Applicability has no stated conditioris that can be entered.

3.4.12 Rx Pressure n

M2 from M1 (See assumption 2.)

3.5.1 ECCS-Op n

M2 from M1 (See assumption 2.)

M3 from M2 to s150psig 3.5.2 ECCS-SD n

ALL Would be MODE change required by ACTIONS of LCO 3.5.1.

Also see Note A.

_ - - _ to U402365 Page 3 of 7 Clinton Power Station October 29, 1994 LCO 3.0.4 EVALUATION Pg 3 LCO New Applbty Comments / Justification l

Allow Xfer (Refer to Page 7) j 3.5.3 RCIC n

M2 from M1 (See assumption 2.)

M3 from M2 3.6.1.1 Cntmt OPER n

M2 from M1 (See assumption 2.)

i M3 from M2 3.6.1.2 Cntmt AirLk n

M2 from M1 (See Note A and assumption 2.)

M3 from M2 i

3.6.1.3 PCI Valves n

M2 from M1 (See Note A and assumption 2.)

M3 from M2 n

Start:

(See assumption 3.)

fuel move.

CORE ALT.

OPDRV M5 from M6 n

M4 from M5.

(See Note A.)

M5 from M4 3.6.1.4 Cntmt Press n

M2 from M1 (See assumption 2.)

M3 from M2 3.6.1.5 Cntmt Temp n

M2 from M1 (See assumption 2.)

M3 from M2 3.6.1.6 LLS Valves n

M2 from M1 (See assumption 2.)

M3 from M2 3.6.1.7 RHR Cntmt n

M2 from M1 (See assumption 2.)

Spray M3 from M2 3.6.1.8 MSIV-LCS n

M2 from M1 (See assumption 2.)

M3 from M2

3. 6. 2.1-Spool Temp n

M2 from M1 (See assumption 2.)

i M3 from M2 3.6.2.2 Spool Lvl n

M2 from M1 (See assumption 2.)

M3 from M2 3.6.2.3 Spool Cool n

M2 from M1 (See assumption 2.)

M3 from M2 3.6.2.4 Spool n

M2 from M1 (See assumption 2.)

Makeup M3 from M2 3.6.3.1 H2 Recm-Op n

M2 from M1 Existing exception to 3.0.4 (and assumption 2.)

3.6.3.2 H2 Igniters n

M2 from M1 Existing exception to 3.0.4 (and assumption 2.)

3.6.3.3 DW Purge n

M2 from M1 Existing exception to 3.0.4 (and assumption 2.)

Sys

- to U402364 hgs 4cf7 Clinton Power Station October 29. 1994 LC0 3.0.4 EVALUATION Pg 4 LCO New Applbty Comments / Justification Allow Xfer (Refer to Page 7) 3.6.4.1 Scndry n

M2 from M1 (See assumption 2.)

Cntmt M3 from M2 n

Start:

(See assumption 3.)

Fuel move, CORE ALT.

OPDRV 3.6.4.2 SCI Valves n

M2 from M1 (See Note A and assumption 2.)

M3 from M2 n

Start:

(See Note A and assumption 3.)

Fuel move.

CORE ALT.

OPDRV 3.6.4.3 SGT Sys n

M2 from M1 (See assumption 2.)

M3 from M2 n

Start:

See Note A and (for 2 inop) assumption 3.

Fuel move.

CORE ALT.

OPDRV 3.6.5.1 DW n

ALL (See assumption 2) 3.6.5.2 DW Air Lock n

ALL (See Note A and assumption 2) 3.6.5.3 DW Isol n

ALL (See Note A and assumption 2)

Vlvs 3.6.5.4 DW Press n

ALL (See assumption 2) 3 6.5.5 DW Temp n

ALL (See assumption 2) 3.6.5.6 DW Vacuum n

ALL (See Note A and assumption 2)

Relief 3.7.1 Div 1 and 2 SX n

M2 from M1 (See assumption 2.)

and UHS M3 from M2 3.7.2 Div 3 SX n

ALL (See Note A.)

3.7.3 CRm Vent n

M2 from M1 (See assumption 2.)

M3 from M2 n

Start:

(See assumption 3 and Note A.)

Fuel move.

CORE ALT.

OPDRV 3.7.4 CRm A/C n

M2 from M1 (See assumption 2.)

M3 from M2 n

Start:

(See assumption 3 and Note A.)

Fuel move.

CORE ALT.

OPDRV

=7

m.

Eclosure 3 to U402364 Page 5 of 7 Clinton Power Station October 29. 1994 LCO 3.0.4 EVALUATION Pg 5 LCO New Applbty Comments / Justification Allow Xfer (Refer to Page 7) 3.7.5 Offgas n

M2 from M1 (See assumption 2.)

M3 from M2 3.7.6 Turb 8ypass n

NA No way to enter Applicability except on startup 3.7.7 Spool Level n

ALL (See assumption 3.)

3.8.1 AC Sources-0P n

M2 from M1 (See assumption 2.)

M3 from M2 3.8.2 AC Sources-SD n

M4 from M3 MODE change required by ACTIONS of LCO 3.8.1.

n M4 from M5.

(See Note A.)

M5 from M4 n

M5 from M6 (Since this activity requires CORE ALTs.

assumption 3 applies.)

{

f n

Start fuel (See assumption 3.)

move 3.8.3 Fuel Oil n

ALL (See Note A.)

l 3.8.4 DC Source-0P n

M2 from M1 (See Note A and assumption 2.)

M3 from M2 3.8.5 DC Source-SD n

M4 from M3 MODE change required by ACTIONS of LCO 3.8.4.

n M4 from MS.

(See Note A.)

M5 from M4 i

n M5 from M6 (Since this activity requires CORE ALTs, i

assumption 3 applies.)

l n

St'..t fuel (See assumption 3.)

rave 3.8.6 Battery Cell n

JLL (See Note A.)

3.8.7 Inverter-OP n

M2 from M1 (See Note A and assumption 2.)

M3 from M2 3.8.8 Inverter-SD n

M4 from M3 MODE change required by ACTIONS of LCO 3.8.7.

n M4 from M5.

(See Note A.)

M5 from M4 n

M5 from M6 (Since this activity requires CORE ALTs.

assumption 3 applies.)

n Start fuel (See assumption 3.)

i move 3.8.9 Distr-OP n

M2 from M1 (See Note A and assumption 2.)

M3 from M2

)

l

)

l

m

.__ to U-602364 i

Page 6 of 7

=

Clinton Power Station October 29, 1994 LC0 3.0.4 EVALUATION Pg 6 LCO New Applbty Comments / Justification Allow Xfer (Refer to Page 7) 3.8.10 Distr-SD n

M4 from M3 MODE change required by ACTIONS of LCO 3.8.9.

n M4 from MS, (See Note A.)

M5 from M4 n

M5 from M6 (Since this activity requires CORE ALTs, assumption 3 applies.)

n Start fuel (See assumption 3.)

move 3.9.1 R/F Intrlck n

ALL (See assumption 3.)

3.9.2 1-Rd-Out Inik n

ALL (See assumption 3.)

3.9.3 CRod Position n

ALL (See assumption 3.)

3.9.4 CRod Pos Ind n

M5 from M4.

(See Note A.)

M5 from M6 J

3.9.5 CRod OP - R/F n

ALL (See assumption 3.)

l 3.9.6 RPV Lvl-Irrd n

ALL (See assumption 3.)

3.9.7 RPV Lvl-New n

ALL (See assumption 3.)

3.9.8 RHR-SDC Hi Lv n

ALL (See Note A.)

3.9.9 RHR-SDC Lo Lv n

ALL (See Note'A.)

3.10.1 Ins Leak /Hyd n

ALL (See assumption 3 and Note A.)

j 3.10.2 Mode Sw Tst n

ALL Assumption 3 and LCO itself precludes entering Applicability.

3.10.3 1 Rd W/-Hot n

ALL See assumption 3 and Note A.

Also LC0 precludes entering applicability.

3.10.4 1 Rd W/-Cold n

ALL See assumption 3 and Note A.

Also LCO precludes entering applicability.

3.10.5 1 Rd W/-RF n

ALL See assumption 3 and Note A.

Also LC0 precludes entering applicability.

3.10.6 Mult Rd W/-

n ALL See assumption 3 and Note A.

Also LCO precludes RF entering applicability.

3.10.7 CRd Tst-0P n

ALL (See assumption 3.)

3.10.8 SDM Tst-RF n

ALL See assumption 3 and Note A.

Also LCO precludes entering applicability.

j 3.10.9 Trng S/U n

ALL (See assumption 3.)

1

=-

-- to U402364 Pap 7 of 7 Clinton Power Station October 29, 1994 LCO 3.0.4 EVALUATION Pg 7 Assumotions 1

1.

Existing LCO 3.0.4 applies to any and all changes in the stated Applicability.

Proposed LCO 3.0.4 only restricts "startup" activities in MODES 1. 2. and 3.

Therefore, this review is evaluating gained MODE change flexibility when:

A) shutting down, and/or B) any change in condition stated in the Applicability while " shut down" 2.

If the ACTIONS ultimately require a shutdown through some MODES in the Applicability, any early shutdown (prior to the absolutely-required shutdown, e.g., the second day of an allowed 7-day restoration) is automatically considered NOT precluded by the existing LC0 3.0.4.

3.

If the ACTIONS to be entered require "Immediate" exit from the Applicability (e.g.. Suspend handling of irradiated fuel -- Immediately) or restoration of compliance with the LCO it is judged to preclude the intentional entry into that Applicability, regardless of LC0 3.0.4.

Notes "Mx" represents " MODE x" "M6" represents DEFUELED A.

There is no gained flexibility since there are no restrictions imposed by the LCO 3.0.4 contained in NUREG-1434 (the ACTIONS permit continued operation in the MODE desired to enter).

B.

The desire to shut down into this MODE results in ACTIONS that require continuation of the shutdown.

Therefore, intentional entry into this MODE as part of a shutdown sequence is not safety significant since the ACTIONS entered are corisistent with the " continued operation" of plant shut down.