ML20029C794

Application for Amend to License NPF-62,revising TS 3/4.1.3.1,3/4.1.3.2 & 3/4.10.2 as follow-up to Util 930416 Application to Correct Noted Surveillance Number Refs to Be Consistent W/License Amend 81 Issued 930715

ML20029C794
Person / Time
Site:	Clinton
Issue date:	04/18/1994
From:	Jackie Cook ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20029C795	List: ML20029C794 RS-92-011, Proposed Tech Specs 3/4.1.3.1, Control Rod Operability, 3/4.1.3.2, Control Rod Max Scram Insertion Times & 3/4.10.2, Rod Pattern Control Sys
References
JGC-003-94, JGC-3-94, RS-92-011, RS-92-11, U-602254, NUDOCS 9404290186
Download: ML20029C794 (5)

Text

-

E liiinois Power Company Cbnton Power Station l

P.O. Box 678 l

Cl.nton. il 61727 l

Tel 217 935-8881. Ext 32c0 Jonn o. Cook Vice Pres. dent ILLINOIS POWER 3cc-oo3-94 April 18, 1994 U-602254 IA7 94(0418)LP 8E.100c Docket No. 50-461 10CFR50.90 Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Clinton Power Station Proposed Amendment of Facility Operating License No. NPF-62: Revision to Technical Specifications 3/4.1.3.1. 3/4.1.3.2. and 3/4.10.2 (RS-92-01!)

Dear Sir:

i Pursuant to 10CFR50.90, Illinois Power (IP) hereby applies for amendment of Facility Operating License No. NPF-62, Appendix A - Technical Specifications, for Clinton Power Station (CPS).

The Technical Specification changes proposed in this application are being submitted as a follow-up to IP letter U-602115 (dated April 16, 1993) and corresponding License Amendment 81 (issued July 15, 1993), which involved the reorganization and renumbering of a particular surveillance requirement.

The proposed changes requested herein are required to correct overlooked references to the renumbered Surveillance Requirement, which were not previously identified and which are contained in the following Technical Specifications: 3/4.1.3.1, " Control Rod Operability,".

3/4.1.3.2, " Control Rod Maximum Scram," and 3/4.10.2, " Rod Pattern Control System."

The requested changes are strictly editorial in nature and involve no changes to the current text or intent of these specifications.

A description of the proposed changes and the associated justification (including the Basis For No Significant Hazards Consideration) are provided in Attachment 2.

Marked-up copies of the afTected pages from the current Technical Specifications are provided in Attachment 3. In addition, an aflidavit supporting the facts set forth in this letter and its attachments is provided in Attachment 1.

9404290186 940418 L

DR ADOCK 05000461 I

i PDR

Page 2 of 2 to U-602254 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 type of efIluents that may be released off-site, nor do they significantly inct ease individual or cumulative occupational radiation exposures. Bases on the foregoing, IP concludes the proposed changes meet the criteria given in 10CFR51.22(c)(9) for a l

categorical exclusion from the requirement for an Environmental Impact Statement.

Sincerely yours, kA./

J. G. Cook Vice President CLJE/csm 1

Attachments cc:

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

4 1

.I

,Ig H

- j --

p to U-602254

.q RS-92-011 Y

j

-i STATE OF ILLINOIS i

COUNTY OF DEWITT l

J, O. 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 application and the facts contained therein are true and correct.

DATE:This /h day of April,1994.

Signed-C

'1. 6.'C"ook Subscribed and sworn to before me this iT _ day of April,1994.

u.iwAN J $htSb t.

_.......... ~ -

~ ~ ~ ~ ~ ~, '

'd.' ~ ~ l otary Public /

S.Matthias

~

L Newy State of unois -

1 MyCommissionExpks11/2M7 t:::::::::::::::u :::::::

J

.i to U-602254 RS-92-Ol l Page1of2 l

Ihc gr_pund/Justifi.gation for Proposed Changes 13y letter U-602115 (dated April 16, 1993), IP requested several changes to the CPS Technical Specifications to provide more flexibility in performing te, ting required during.

plant startup. These proposed changes were approved by the NRC and incorporated via-License Amendment 81 (NRC letter dated July 15, 1993). Included in the approved changes is a change to the Surwillance Requirement (s) for performing scram insertion time testing of control rods (on which maintenance or modifications were performed during an outage) which will allow such testing to be done at low reactor pressure prior to -

reactor startup. This change did not eliminate the requirement to perform scram-time testing of all control rods prior to exceeding 40% power, but it does potentially-provide relief to plant operators by not requiring such testing to be done during a particularly active and stressful period during plant startup when other important evolutions and required testing are being performed.

Prior to the above change, all control rod scram-time testing requirements were specified within Surveillance Requirement 4.1.3.2 (parts "a", "b" and "c").

Implementation of the 4

above-described change necessitated reorganizing Specification 4.1.3.2 and splitting it into

{

Specifications 4.1.3.2.1 (parts "a" and "b") and 4.1.3.2.2 as reflected in Amendment 81 (NRC letter dated July 15, 1993).

Specifically, former Specification 4.1.3.2.b was a

rewritten (to include the low-pressure testing option described above) and renumbered to become Specification 4.1.3.2.2.

Consequently, former Specifications 4.1.3.2.a and 4.1.3.2.c were renumbered to become Specifications 4.1.3.2.1.a and 4.1.3.2.1.b, respectively.

Subsequent to receipt of Amendment 81, it was recognized that some references to Specification 4.1.3.2 elsewhere in the Technical Specifications had been overlooked.' That is, the need to update these Technical Specifications with the renumbered Surveillance Requirement (s) was not identified. Due to this oversight, IP herein submits follow-up changes to correct the suneillance number references identified in the Technical Specifications.

Desgiption of Proposed Change _s in accordance with 10CFR50.90, the following changes are being proposed:

(1) TS 3/4.1.3.1, " Control Rod Operability," is being revised to correctly refer to the surveillance numbers reflected in Amendment 81 by replacing "4.1.3.2" in Surveillance Requirement 4,13.1.3 with "4.1.3.2.1" and "4.1.3.2.2."

(2) TS 3/4.1.3.2, " Control Rod Maximum Scram Insertion Times," is being revised to correctly refer to the surveillance numbers reflected in Amendment 81 by replacing "4.1.3.2.a or b" in Action "a" with "4.1.3.2.1.a or 4.1.3.2.2," replacing "4.1.3.2.c" in Actions "b" and "c" with 4.1.3.2.1.b," and replacing "4.1.3.2.a and b" in Action "c" with "4.1.3.2.1.a and 4.1.3.2.2."

to U-602254 RS 92-011 -

Page 2 of 2 (3) TS 3/4.10.2, " Rod Pattern Control System," is also being revised to correctly refer to the surveillance numbers reflected in Amendment 81 by replacing "4.1.3.2" within part "b" of the Limiting Condition for Operation with "4 l.3.2.l_and 4.1.3.2.2."

The proposed changes are reflected on the marked-up copies of pages from the CPS Technical Specifications contained in Attachment 3.

Ilasis for Ngjigrt ficantilatardtConsidstation i

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, (2) create the possibility of a new or ditTerent kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. The proposed changes are collectively evaluated against these criteria as follows.

r The changes proposed herein are only editorial in nature. They merely correct the noted surveillance number references to be consistent with Amendment 81 without making any changes to the text or intent of the afTected Surveillance Requirements.

(1)

These changes do not affect the intent or implementation of the applicable Technical Specifications. The changes simply make the alTected Technical Specifications consistent. Since these are only editorial changes which do not impact the plant design or operations, they cannot increase the probability or the consequences of any accident previously evaluated.

(2)

The proposed changes are editorial only and do not affect the plant design or operation. No new failure modes are introduced by such changes and, therefore, the request will not create the possibility of a new or difTerent kind of accident from any accident previously evaluated.

(3)

The proposed changes merely correct an editorial oversight. These changes do not alter or' delete any technical requirements, and therefore do not involve a reduction in a margin of safety.

13ased upon the foregoing IP concludes that these changes do not involve a significant hazards consideration.

7

+

M k

4 i-,

y