U-602355, Revises 940812 Application for Amend to License NPF-62, Revising TS 3/4.6.2.2, Drywell Bypass Leakage, to Incorporate NRC Recommendation of five-yr Drywell Bypass Leakage Test (Dblrt) Instead of 10-yr Dblrt
| ML20076G258 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 10/14/1994 |
| From: | Jackie Cook ILLINOIS POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20076G261 | List: |
| References | |
| JGC-300-94, U-602355, NUDOCS 9410190208 | |
| Download: ML20076G258 (3) | |
Text
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!!!inois Power Cornpany.
Chnton Power Station E
9 P 0, Box 678 6
Cknton. IL 61727
'+
Tel 217 93s 5623 Fax 217 93s-4632 John G. Cook Vice President ILLINSIS uouss P6MR U7-94(10 -14 )LP 8E.100 JGC-300-94 October 14, 1994 Docket No. 50-461 10CFR50.90 -
Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Clinton Power Station Revision to Previously Submitted Proposed Amendment of Facility Operating License No. NPF-62 [LS-94-006) (
Reference:
Illinois Power Letter U-602320. dated August 12.1994)
Dear Sir:
By letter dated August 12,1994 lilinois Power (IP) submitted an application for amendmer. of the Clinton Power Station fCPS) Operating License (License No. NPF-62) to incorporate a p.oposed change to the CPS Technical Specifications (Appendix A).
Specifically, IP proposed to revise Technical Specification 3/4.6.2.2, "Drywell Bypass Leakage," to allow drywell bypass leakage tests (DBLRTs) to be performed at intervals of up to ten years based on the demonstrated performance of the drywell barrier with respect to leak tightness. In the event of a DBLRT failure, the frequency would be required to be increased to at least once per 36 months. If the' subsequent DBLRT meets the leakage limit, the ten-year schedule would be permitted to be resumed. In the event of two consecutive DBLRT failures, the frequency would be required to be increased to at least once per 18 months until two consecutive DBLRTs meet the limit, at which time the ten-year schedule would be permitted to be resumed.
Recent discussions with the NRC Licensing Project Manager for CPS indicate that the NRC stafThas completed its technical review ofIP's application. The NRC staff has determined that IP's request is acceptable except for the proposed length (ten years) of the increased test interval. The Staffs position (Containment Systems and Severe Accident Branch)is that a five-year interval is more appropriate. Although the DBLRT is not subject to the requirements and provisions of 10CFR50 Appendix J, the Staff has indicated that a five-year DBLRT test interval is consistent with the five-year test interval currently -
being considered for Type C local leak rate testing (of containment isolation valves) pursuant to the currently proposed revision of10CFR50 Appendix J 9410190200 941014 PDR ADOCK 05000461 (f}
P PDR g
y U-602355 Page 2 IP's position that a ten-year test interval is appropriate for CPS, based on the reasons provided in its August 12 application, remains unchanged. However,in the interest of obtaining NRC approval of a license amendment that supports an extension of the current test interval in sufficient time to support the upcoming refueling outage, IP accepts the NRC staffs recommendation of a five-year DBLRT test interval and is thus proposing to revise the August 12,1994 application. Further action to again propose extending the DBLRT to a ten-year interval may be considered at a future time.
To revise the August 12,1994 application, IP proposes that wherever the proposed Technical Specification and associated. Bases changes (as indicated in the August 12 submittal) refer to "10 years," "10-year schedule," "10 year Frequency," or "120 months," these references be changed correspondingly to "5 years," "5-year schedule," "5 year Frequency," and "60 months." A revised marked-up copy of the affected page from the current CPS Technical Specifications is provided in Attachment 2 to this letter. (This marked-up page replaces the marked-up page originally provided in to U-602320.) A revised marked-up copy of the affected pages from IP's request to convert to the Improved Standard Technical Specifications (reference: IP Letter U-602196 dated October 26,1993)is provided in Attachment 3. (The pages provided in are based on the marked-up pages prosided in Attachment 4 to U-602320.
As the marked-up pages have been revised, Attachment 3 supersedes Attachment 4 to U-602320. Further, because these pages already contain mark-ups, the above-described changes (to reflect a five-year DBLRT test interval) are specifically indicated by use of double revision bars.) In addition, an aflidavit supporting the facts set forth in this letter and its attachments is provided in Attachment 1.
With further respect to the changes described in this letter and their impact on IP's originally proposed change, it should be noted that the Basis for No Significant Hazards Consideration as evaluated by IP in its August 12 submittal remains unchanged. In addition, IP's evaluation of the proposed change against the criteria of 10CFR51.22 also i
remains unchanged such that the proposed change still meets the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the s eguirement for an Environmenta!
Impact Statement.
Sincerely yours,
/.G. Cook Vice President i
l TBE/csm cc:
NRC Clinton Licensing Project Manager NRC Resident Oflice, V-690 Regional Administrator, Region III, UShTC Illinois Department of Nuclear Safety i
4 Attachment I to U-602355 L G. Cook, being first duly sworn, d6 poses and says: That he is Vice President ofIllinois Power; that this 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.
l l
Date: This i day of October 1994.
i Signed:
[
A L G. Cook 0FRCN. M '
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i Subscribed and sworn to before me this /[ day of October 1994.
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/ potary Public[
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