U-600885, Forwards marked-up Revs to Tech Specs Re Setpoints for Lpcs/ LPCI Permissive Interlocks for Full Power Ol,As Suppl to Util 870108,0204 & 0303 Ltrs.Changes Consistent W/Fsar & SER Through Suppl 7.No Change to Low Power OL Requested

Forwards marked-up Revs to Tech Specs Re Setpoints for Lpcs/ LPCI Permissive Interlocks for Full Power Ol,As Suppl to Util 870108,0204 & 0303 Ltrs.Changes Consistent W/Fsar & SER Through Suppl 7.No Change to Low Power OL Requested

ML20204F045
Person / Time
Site:	Clinton
Issue date:	03/20/1987
From:	Hall D ILLINOIS POWER CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
U-600885, NUDOCS 8703260127
Download: ML20204F045 (19)

Text

'

U-600885 L30- 87(03-20) -L 8E.110 ILLINO/S POWER COMPANY CLINTON POWER STATION. P.O. BOX 678. CLINTON. ILLINOIS 61727 t,mR 2 01987 Docket No. 50-461 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Clinton Power Station Technical Specifications

1. cr Full Power Operating License

Dear Mr. Denton:

This letter supplements Illinois Power Company's (IP) letters dated January 8, 1987 (U-600785), February 4, 1987 (U-600817), and March 3, 1987 (U-600848) and provides additional changes that IP requests be included in the Technical Specifications (CPS-TS) which will accompany the full-power operating license for Clinton Power Station.

Additionally, information is being supplied to clarify the NRC concerns pertaining to changes in CPS-TS setpoints for the LPCS/LPCI permissive interlocks (U-600848). These changes represent clarification and enhancements to the CPS-TS and have been discussed with your Mr. B. L. Siegel, Clinton NRC Project

^

Manager. The justifications and the proposed marked-up pages are attached. None of these changes affect IP's ability to safely operate the Clinton Power Station under its current license. Therefore, no amendment to the present low-power license (NPF-55) is being requested.

These changes to the CPS-TS have been reviewed and are consistent in all material aspects with the FSAR as amended, the Safety Evaluation Report and its Supplements Nos. 1-7 and the as-built plant. An affidavit relating to this certification accompanies this letter.

If you have any questions or require additional information, please contact me.

,J S erel yours, 8703260127 870320 PDR ADOCM 05000461

. . Hall Vice President RFP/bsa Attachment pol llt

• U-600885 L30- 87(03-20)-L 8E.110 cc: B. L. Siegel, NRC Clinton~ Licensing Project Manager NRC Regional Administrator, Region III NRC Resident Office Illinois Department of Nuclear Safety 4

f

\

. U-600885 L3 0- 87(03-20)-L 8E.110 STATE OF ILLINOIS i

COUNTY OF DEWITT DONALD P. HALL, Being first duly sworn, deposes and says: That he is Vice President of Illinois Power Company; that the information provided in letter U-600885 to certify that the Clinton Power Station (CPS) Technical Specifications are consistent with the CPS - Final Safety Analysis Report, the NRC Safety Evaluation Report and the as-built facility, 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 request and the facts contained therein are true and correct.

-il.

DATED: ThisMd day of March 1987 l'

\

Signed:

Donald 4. Hall Subscribed and sworn to before me thisc7t2r/ day of March, 1987.

& /xWD 64+1 W t <}

Notary Public My commission expires:

k tus u. // JVGh r

)

- Attachmsnt to U-600885 Page 1 of 16 Description of Change Specification 3/4.6.1.7, page 3/4 6-11. Add a note to define the requirements for " arithmetical average" and provide for continued plant operation and flexibility in performance of instrument maintenance which may render the subject instrument inoperable.

1

• The arithmetical average shall consist of at least one '

reading from one location per quadrant of the above locations. However, all available instruments should be used in determining the arithmetical average.

Justification Unlike other instrumentation Specifications, this Specification has no provisions for continued plant operation if the subject instruments are found to be inoperable or if the subject instruments are rendered inoperable by the performance of planned maintenance or testing. Other instrumentation Specifications consider a minimum-operable-channels concept in evaluating conditions for continued plant operation. Other Specifications also recognize that surveillance and maintenance are commonplace requirements and that operation of the plant should not be jeopardized as long as minimum requirements are fulfilled.

l This Specification utilizes redundant instrumentation in each quadrant. Containment temperature instrumentation contained in l Specification 3/4.3.7.5, Accident Monitoring Instrumentation, is l additional and separate from this Specification, and has

requirements for operability contained therein. The instruments

of this Specification do not provide any automatic initiation /

! actuation of safety-related systems. The addition of this note establishes a minimum requirement of four instruments, consisting of at least one in four quadrants of the containment. In addition, the note requires the operator to use all available

! instrumentation of this Specification in determining the arithmetical average temperature.

This change is consistent with the NRC's policy as exhibited by the NRC's issuance of similar Specifications (attached) in the

, full power operating license of the Perry Nuclear Plant (NUREG-1204 page 3/4 6-11).

- r ATTACBIENr ta C-600885 CONTAllMENT SYSTEMS  !

PRIMARY CONTA100 TENT AVERAGE AIR TEMPERATURE LIMITING CONDITION FOR OPERATION

3. 6.1. 7 Primary containment average air temperature shall not ex'ceed 122 F.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

With the primary containment average air temperature greater than 122*F, reduce the average air temperature to within the limit within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at  !

least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUT 00WN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.1.7 The ical average of *the primary containment temperatures average at the following air temperature locations and shall beshall be the arithmet- l determined to be within the limit at least once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

Elevation Azimuth Division

a. 778' - 0" 82' I

b. 778' - 0" 105* I

c. 778' - 0" 170' II

d. 778' - 0" 190' II

e. 778' - 0" 262* I

f. 778' - 0" 284' II

g. 778' - 0" 335' I

h. 778' - 0" 29 II IP45Y one

-W 7he ar'il-hee-lical average shall censist o f ad a loca4 ion per quadrand o4' Me above rends'63 from one Hoso e ve r , all aca'ilable in ,f ru e1 cnis s hould

~ locellons.

be u s c el in dc.4er mining 4he. aci4 hmc4ical aver 43e.

CLINTON - UNIT 1 3/4 6-11

ATTACBMENT ts U-600885 Pzge 3 af 16 CONTAlletENT SYSTEMS l' PRIMARY CONTAIM4ENT AVERAGE AIR TEMPERATURE LIMITING CONDITION FOR OPERATION 3.6.1.7 Primary containment average air temperature shall not exceed 90*F.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2 and 3.

ACTION:

With the primary containment average air temperature greater than 90*F, reduce the average air temperature to within the limit within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.1.7 The primary containment average air temperature shall be the arith-metical average

• of the temp'eratures at the following locations and shall be determined to be within the limit at least once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

1 I

Elevation Azimuth

. ' ' ~

'a . '72'0 ' - 6" 280'*

b. 720'-6" 100*

c. 689'-4" 40*

d. 689'-4" 210*

e. 647'-0" 54*

f. 645'-6" 251

g. 613'-0" 69*

h. 613'-0" 251*

• At least one reading from each elevation for an arithmetical average. However, I all available instruments should be used in calculating the arithmetical average.g 4ERRY - UNIT 1 3/4 6-11

. Attachmsnt to U-600885 Page 4 of 16 Description of Change Specification 3/4.6.2.6, page 3/4 6-20. Add the following notes to define the requirements for " arithmetical average" and provide for continued plant operation and flexibility in performance of instrument maintenance which may render the subject instrument inoperable:

• The arithmetical average shall consist of at least one reading from each of the above listed elevations.

However, all available instruments should be used in determining the arithmetical average.

f The instruments at a. and h. are considered to be at the same elevation.

Justification Unlike other instrumentation Specifications, this Specification has no provisions for continued plant operation if the subject instruments are found to be inoperable or if the subject-instruments are rendered inoperable by the performance of planned maintenance or testing. Other instrumentation Specifications consider a minimum-operable-channels concept in evaluating conditions for continued plant operation. Other Specifications recognize that surveillance and maintenance are common-place requirements and that operation of the plant should not be jeopardized as long as minimum requirements are fulfilled.

This Specification utilizes redundant instrumentation for each listed elevation. Drywell Temperature instrumentation contained in Specification 3/4.3.7.5, Accident Monitoring Instrumentation, is additional and separate from this Specification, and has requirements for operability contained therein. The instruments of this Specification do not provide any automatic initiation /

actuation of safety-related systems.

The addition of these notes establishes a minimum requirement of seven instruments, consisting of at least one in each of the elevations of the drywell. In addition, note

• requires the operator to use all available instrumentation of this Specification in determining the arithmetical average.

This change is consistent with the NRC's policy as exhibited by the NRC's issuance of similar Specifications (attached) in the

- full power operating license of the Perry Nuclear Plant (NUREG-1204 page 3/4 6-21).

l

14

. ATTACIDENT to G-600885 I P g2 5 ef 16  !

CONTAllmENT SYSTEMS  ;

DRYWELL AVERAGE AIR TEMPERATURE LIMITING CONDITION FOR OPERATION 3.6.2.6 Drywell average air temperature shall not exceed 135*F. .

APPLICABILITY: OPERATIONAL CONDITIONS'l,.2, and 3.

ACTION:

With the drywell average air temperature greater than 135*F, reduce the average air temperature to within the limit within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.2.6 The drywell average air temperature shall be the arithmetic averageE of the temperatures at the following locations and shall be determined to be within the limit at it.ast once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

Instrument Number Elevation Azimuth

a. ITE-VP033A 729'-0" M 45 l

b. ITE-VP033B 775'-0" 160

c. ITE-VP033C 741'-0" 45*

d. ITE-VP033D 772'-0" 130

e. ITE-VP033E 802'-0" 0*

f. ITE-VP033F 746'-0" 307*.  !

g. ITE-VP033G 794'-0" O' i

h. ITE-VP034A 732'-0" # 225' l l

1. ITE-VP034B 775'-0" 230*

j. ITE-VP034C 741'-0" 220

k. ITE-VP034D 772'-0" 235*

l

1. ITE-VP034E 802'-0" 180*

m. ITE-VP034F 746'-0" 135*

n. ITE-VP034G 794'-0" 180 W 'The oriem4ical cutonqc shall consist of 44 least one reading -From each oT 4 he, a.bove listed eleva+ ions.

Homver oll ctvaila bic- instruments .s hou ld be used in de+e'rmining +h e a r im metica l av erag e.

l

• 77)e inskamenh at a . and h. a re cca s idered do . be.

a+ +he same elevadion.

CLINTON - UNIT 1 3/4 6-20

j r

ATTACIDGENT to C-600885

- P gs 6 ef 16 CONTAIl0ENT SYSTEMS

~

DRWELL AVERAGE AIR TEMPERATURE LIMITING CONDITION FOR OPERATION l

3.6.2.6 Drywell average air temperature shall not exced 135*F.

APPLICABILITY: OPERATONAL CONDITIONS 1, 2 and 3.

ACTION: ,

l With the drywell average air temperature greater than 135*F, reduce the average air temperature to within the limit within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENTS , 4.6.2.6 The drywell average air temperature shall be the arithmetical average

• of the temperatures at the following locations and shall be determined to be within the limit at least once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

l Elevation Azimuth

. a. 653'-8" 315*

! b. 653'-8" 135*

! c. 634'-0" 308'

d. 634'-0" .

~

145? '

l e. 605'-0"# 308*

f. 604'-6"# 150*

1

• At least one reading from each elevation for an arithmetical average. However, all available instruments should be used in calculating the arithmetical average.

1. The instruments at e. and f. are considered to be at the same elevation.

i e

PERRY - UNIT 1 3/4 6-21 l

Attachment to U-600885 Page 7 of 16 Description of Change Specification 4.8.2.1.d.2.a), b), and c), pages 3/4 8-13 and 3/4 8-14. Revise the load profile for the Division I, II, and III batteries as indicated in the marked-up page.

Justification As indicated in the Clinton Power Station Safety Evaluation Report, NUREG 0853 (SER) Section 9.6.6, the NRC Staff required the installation of a prelubrication system (equivalent to that described in EMD's MI-9644) that meets the manufacturer's recommendation. This prelubrication system installation has been completed and, as a result, certain changes are required to the Technical Specifications to account for the load of the DC powered prelubrication pump motor In addition to adding the load of the prelubrication pump motor, IP has reevaluated the actual loads, based on the as-built configuration, instead of using conservative estimates to determine the load profile. In the case of the Division III battery, the actual load evaluation has resulted in an overall decrease in the total battery load as shown in the revised load profile in the change to the Technical Specifications. These added loads are not significant with respect to battery capacity, and analysis in accordance with IEEE 485 has shown that the batteries are capable of supplying the new loads now and at the end of their twenty year life. Battery testing requirements in IEEE 450 do not require retesting for small load additions. As this change in load is not substantial, no retesting will be performed.

Changes to Tables 8.3-8, 8.3-9, and 8.3-10 and subsections 9.5.5.5, 9.5.7.2., 9.5.7.5, Q&R 40.58, Q&R 40.60, and associated figures in the Clinton Power Station Final Safety Analysis Report (FSAR) will be made in the next FSAR submittal.

I

ATTACHMENT to U-600885 Page 8 of 16 ELECTRICAL POWER SYSTEMS DC SOURCES - OPERATING

~

SURVEILLANCE REQUIREMENTS (Continued) 4.8.2.1 (Continued) b.

At least once per 92 days and within 7 days after a battery discharge with battery terminal voltage below 110 volts, or battery overcharge with battery terminal voltage above 150 volts, by verifying that:

1.

The parameters in Table 4.8.2.1-1 meet the Category 8 limits, 2.

There is no visible corrosion at either terminals or connectors, or the connection resistance of these items is less than 150 x 10 5 ohms, and 3.

The average electrolyte temperature of the pilot cells and representa-tive cells

• of connected cells is above 65*F.

c. At least once per 18 months by verifying that:

" 1.

The cells, cell plates and battery racks show no visual indication ,

of physical damage or abnormal deterioration, 2.

The cell-to-cell and terminal connections are clean, tight, free of corrosion and coated with anti-corrosion material,

3. The resistance of each cell-to-cell and terminal connection is than or equal to 150 x 10.s ohms, and 4.

The battery charger will supply at least 300 amperes for Divisions I and II and 100 amperes for Division III and IV at a minimum of 125 volts for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

d.

At least once per 18 months, during shutdown, by verifying that either:

1.

The battery capacity is adequate to supply and maintain in OPERABLE status all of the actual emergency loads for the design duty cycle when the battery is subjected to a battery service test, or 2.

The battery capacity is adequate to supply a dummy load of the follow-ing profile while maintaining the battery terminal voltage greater than or equal to 105 volts.

a) Division I_

>54[mperesforthefirst60 seconds M/ mperes for the next 59 minutes 2.3 14T b peres for the next 180 minutes

• IEEE-450 shall be used for the purpose of defining representative cells.

3/4 8-13 CLIN:GN - UNIT 1

i ATTACIDerT to U-600885 Pega 9 ef 16 ELECTRICAL POWER SYSTEMS DC SOURCES - OPERATING SURVEILLANCE REQUIREMENTS (Continued)

~

l 4.8.2.1 (Continued) b) Division II N Y>48[amperesforthefirst60 2 # amperes for the next 59 minutes seconds y 7[ amperes for the next 180 minutes l 7 c) Division III

> # amperes for the first 60 seconds

'f2 -54^1mperes for the next 239 minutes g

d) Division IV

> 127 amperes for the first 60 seconds

> 117 amperes for the next 59 minutes

[44amperesforthenext180 minutes

e. At least once per 60 months, during shutdown, by verifying that the battery capacity is at least 80% of the manufacturer's rating when subjected to a performance discharge test. Once per 60 month interval, this performance discharge test may be performed in lieu of the battery service test.

f. At least once per 18 months, during shutdown, performance discharge tests of battery capacity shall be given to any battery that shows signs of degra-dation or has reached 85% of the service life expected for the application.

Degradation is indicated when the battery capacity drops more than 10% of rated capacity from its average on previous performance tests, or is below 90% of the manufacturer's rating.

CLINTON - UNIT 1 3/4 8-14 l

Attachmsnt to U-600885 Page 10 of 16 Description of Change

Specification 3/4.3.7.8 and BASES, pages 3/4 3-92 and B 3/4.3-7; Specification 3/4.7.2, page 3/4 7-5. Modify the appropriate Specifications;to account for alternate methods for use and storage of chlorine gas on site.

Justification The Clinton Power Station Final Safety Analysis Report (FSAR)

, provided results of the protection of control room operators against the accidental release of chlorine as required by the guidance presented in Regulatory Guide 1.95. As described in the FSAR, a major contributor to the chlorine hazard is the storage of chlorine in individual containers having an inventory of

greater than 150 pounds.

h Regulatory Guide 1.95, position C.2 allows a manual isolation capability of the control room HVAC (VC) system if chlorine is stored in containers with an individual inventory of less than 150 pounds and at a distance from the control room of greater than 100 Meters.

Clinton Power Station (CPS) has evaluated its methods of use and storage of chlorine within the owner controlled area on site.

CPS has evaluated methods to reduce the hazard presented by the current practice of using chlorine in individual containers of one ton capacity. CPS plans to reduce the use of gaseous chlorine in treatment of water systems.

IP intends to remove individual containers of chlorine weighing greater than 150 pounds, i.e., 1 ton containers, and eventually

establish a solid or liquid water treatment system.

Until such time that a new system for water treatment can be made L operational, the CPS Technical Specifications should be revised

! to accommodate operation with the reduced hazard comprised of l storage of chlorine within the criteria of acceptance in position

) C.2 of Regulatory Guide 1.95. That is, chlorine will be stored f in containers with individual capacities of less than or equal to

! 150 pounds at a distance of greater than 100 Meters (CPS actual distance is 126 Meters) from the nearest control room intake.

! Clinton Pcwer Station has surpassed the initial fuel load milestone. Note should be deleted.

i BASES 3/4.3.7.8 should be revised to show the automatic j initiation of the VC system chlorine mode of operation is not necessary when chlorine is stored in individual containers of less than or equal to 150 pounds.

l r

l o

Attachment to U-600885 Page 11 of 16 Specification 4.7.2.e.2 should be appropriately footnoted to reveal that automatic transfer, to the chlorine mode of operation, is not required unless chlorine is stored, within the owner controlled area, in containers with individual capacities of greater than 150 pounds.

ATTACBGDIT to U-600885 Pega 12 of 16 l INSTRUMENTATION CHLORINE DETECTION SYSTEM LIMITING CONDITION FOR OPERATION 3.3.7.8 Two independent chlorine detection channels shall be OPERhBLE i l

with 5 the @ir trip setpoints adjusted to actuate at a chlorine concentration 5 ppm. l APPLICABILITY: All OPERATIONAL CONDITIONS and *.

ACTION:

a. With one chlorine detection channel inoperable, restore the inoperable detection channel to OPERABLE status within 7 days, or within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, initiate and maintain operation of at least one control room emergency filtration system subsystem in the chlorine mode of operation.

b. With both chlorine detection channels inoperable, within I hour initiate and maintain operation of at least one control room emergency filtration system subsystem in the chlorine mode of operation.

c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.7.8 Each of the above required chlorine detection channels shall be demonstrated OPERABLE by performance of a:

a. CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />,

b. CHANNEL FUNCTIONAL TEST at least once per 31 days, and

c. CHANNEL CALIBRATION at least once per 18 months.

• When irradiated fuel is being handled in the secondary _ containment. M TThe operability requirement for the chlorine detection system is suspended until the initial fuel load is completed and prior to placing the reactor mode switch in STARTUP for the initial criticality.

CLINTON - UNIT 1 3/4 3-92

ATTACIDIENT to U-600885 INSTRUMENTATION I

i BASES 3/4.3.7.7 TRAVERSING IN-CORE PROBE SYSTEM (Continued) by comparing the detector (s) output with data obtained during the previous LPRM

( calibrations.

3/4.3.7.8 CHLORINE DETECTION SYSTEM

• The OPERABILITY of the chlorine detection system ensures that an accidental chlorine release will be detected promptly and the necessary protective actions will be automatically initiated to provide protection for control room personnel.g Upon detection of a high concentration of chlorine, the control room ventilation system will automatically be placed in the chlorine mode of operation to provide

. the required protection. The detection systems required by this specification are consistent with the recommendations of Regulatory Guide 1.95, " Protection of Nuclear Power Plant Control Room Operators Against an Accidental Chlorine Release," January, 1977.

3/4.3.7.9 FIRE DETECTION INSTRUMENTATION

• Deleted 3/4.3.7.10 LOOSE-PART DETECTION SYSTEM The OPERABILITY of the loose-part detection system ensures that sufficient capa-bility is available to detect loose metallic parts in the primary system and avoid or mitigate damage to primary system components. The allowable out of-service times and surveillance requirements are consistent with the recommenda-tions of Regulatory Guide 1.133, " Loose-Part Detection Program for the Primary I System of Light-Water-Cooled Reactors," May 1981.

,h l

/

AadomOc. ini k hon is onIq reguired Ae n chlo6n e h 54cred usiM in +ke owner conhlkd '

area in coniainecs m% indsidmi ca.pa c i +ie 5 o{ greed er than 150 pands CLINTON - UNIT 1 B 3/4 3-7

r, ATTACIDENT ts U-600885 8' I I' PLANT SYSTEMS C0KfROL ROOM VENTILATION SYSTEM 7

SURVEILLANCE REQUIREMENTS (Continued) ,

4.7.2 (Continued) ,

1

d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying within l 31 days af ter removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Positior C.6.b of Regulatory Guide 1.52, Revision 2, March 1978*, meets the laboratory test- '

ing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978*, for a methyl iodide penetration of less than 0.175% for the makeup filt2r system carbon adsorber and 6% for the retir-culation filter system carbon adsorber when tested; in accordance with ASTM ,

D3803-70 methods, with the following parameters:  !

Make Up Filter System a) Bed Depth -

4 inches b) Velocity -

40 fpm c) Temperature -

30 C d) Relative Humidity -

70%

Recirculation Filter System a) Bed Depth -

2 inches b) Velocity -

80 fpm c) Temperature -

30 C d) Relative Humidity -

70%

e. At least once per 18 months by:

. 1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6 inches Water Gauge while operating the makeup filter system at a flow rate of 3000 cfm i 10%.

-r

2. Verifying that on a high chlorine actuation #/and a manual initia-tion test signal, the system automaticall/$ witches to the chlorine j mode of operation and the dampers close within 2 seconds.

l

3. Verifying that the control room leak rate is limited to < 4000 cfm i 10% at > 1/8-inch Water Gauge (W.G.) with respect to a3jacent areas.

4. Verifying that on a smoke mode actuation test signal, the system

! automatically switches to the smoke mode of operation at a flow rate less than or equal to 64,000 cfm i 10%.

5. Verifying that on a high radiation actuation test signal, the system l

automatically switches to the high radiation mode of operation and i

• ANSI N510-1980 shall be used in place of ANSI N510-1975 as referenced in Regulatory Guide 1.52, Revision 2, March 1978.

LhTON-UNIT 1 3/4 7-5 Amendnent No.1 ddondie %h- lo & chlor lnc Nalc }s ild reguired unles.s d>Isrin e un sufowaLaufM 4de ca ner cadto//cd area in cen-/uine sr toHb cap. h 150 lh .

Attachm nt to U-600885 Page 15 of 16 Description of Change Table 3.3.3-2 page 3/4 3-39, 40. Submitted dated March 3, 1987 U-600848.

Justification Page 5 of 23 of the attachment to letter U-600848 presented changes to the CPS-TS. The NRC's Messrs. B. Siegel and D. Katze expressed concerns over the change in the analytical limit for the subject setpoint change.

The analytical limit for the LPCI/LPCS injection valve permissive was changed from 454 psig to 415 psig. The new analytical limit is conservatively less than the existing analytical limit.

The interlocks serve two functions:

To inhibit opening of the LPCI and LPCS injection valves to the Reactor when the reactor pressure is above the piping design pressure of the LPCI and LPCS systems, and To permit opening of the LPCI and LPCS injection valves to the Reactor when safety injection is required for core cooling following a Loss of Coolant Accident (LOCA).

These two interlock functions are satisfied by establishing an upper Analytical Limit below which the design pressure of the piping can permit opening of the injection valves, and a lower Analytical Limit above which opening of the injection valves can be accomplished soon enough to provide adequate core cooling following a LOCA. A setpoint is chosen between the upper and lower Analytical limits such that, with predicted instrument loop inaccuracies, both functions of the interlock will be assured.

The Clinton specific setpoint represents a response to the NRC requirements on setpoint methodology including effects of environmental parameters. As described in the previous submittal (U-600848) these instruments were susceptible to inaccuracies because of exposure to radiation doses typical of a LOCA. The l cause of this inaccuracy is excessive conservatism in radiation source term values, the severity of which was not foreseen at the l time the instrument system was designed and purchased. This condition has been analyzed and this concern does not constitute a substantial safety hazard. The overall change in PCT due to this evaluation of the interlock function and change in analytical limit has resulted in an increase of approximately 18*F in PCT.

Attachment to U-600885 Page 16 of 16 Additionally, CPS has continued its participation in the BWROG Instrument Setpoint Methodology Program (ISM), and as a result, evaluated and made changes to analytical limits for Reactor Water Level measurement, LL1, LL2 and LL3. In essence, CPS has accounted for Process Measurement Accuracy (PMA) in the methodology for Reactor Water Level LL1, LL2 and LL3. This increase in the CPS specific analytical limit was analyzed and has contributed a 1 F change to PCT. The existing analytical limits for the respective level are presented as follows:

Existing New Analytical Limit Analytical Limit LL1 -150 in. -152.6 in.

LL2 - 50 in. - 52.6 in.

LL3 +7.7 in. + 7.6 in.

These changes are all in the conservative direction and therefore no Technical Specification changes are required.

In June of 1986, CPS met with NRC and discussed closure times for those systems penetrating containment. As a result, CPS included in the CPS-TS BASES 3.6.4 the criteria for determining valve operability when evaluating the stroke time of the subject valves.

Subsequently CPS has evaluated relaxations in system requirements for the bounding times determined by CPS-TS 3.6.4 BASES. The baseline value was obtained by actual testing (actual valve time 20 sec.). This relaxation of the LPCI and LPCS injection valves lE12F042AC and lE12-F005 respectively was evaluated for the subject system performance in the Plant Specific ECCS analysis.

The overall.effect was an increase in PCT of 15 F.

A new ECCS analysis has been performed for Clinton considering the following changes to three above described input parameters:

1) Updated analytica) limits for LPCI/LPCS injection valves permissive.

2) Updated analytical limits for level setpoints LL1, LL2 and LL3, and

3) MOV closure time relaxations.

The assessment for the Design Basis Accident-recirculation suction line break with LPCI D/G failure (Reference CPS-FSAR Table 6.3-3) - has yielded a PCT increase by 34 F and the oxidation fraction will increase by 0.003. Since PCT for the previous FSAR case is 2071 F there is sufficient margin available to the 2200*F limit of 10CFR50.46 to absorb the increase resulting from reanalysis.

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