ML090710868

Licensed Amendment, Adopted TSTF-2, Relocate the 10-year Sediment Cleaning of the Fuel Oil Storage Tank to Licensee Control

ML090710868
Person / Time
Site:	Clinton
Issue date:	04/02/2009
From:	Sands S Plant Licensing Branch III
To:	Pardee C Exelon Generation Co
Sands, S.P., NRR/DLPM/LPD III-2, 415-315
References
TAC MD9589
Download: ML090710868 (11)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 2, 2009 Mr. Charles G. Pardee President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

CLINTON POWER STATION, UNIT NO.1 - ISSUANCE OF AMENDMENT RE:

LICENSE AMENDMENT REQUEST TO ADOPT TSTF-2, "RELOCATE THE 10 YEAR SEDIMENT CLEANING OF THE FUEL OIL STORAGE TANK TO LICENSEE CONTROL" (TAC NO. MD9589)

Dear Mr. Pardee:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 186 to Facility Operating License No. NPF-62 for the Clinton Power Station (CPS), Unit NO.1. The amendment is in response to your application dated September 2, 2008, (Agencywide Document Access and Management System (ADAMS) Accession No. ML082470688).

The amendment requested to amend the CPS Unit NO.1 Technical Specifications (TS) to relocate the TS surveillance requirement (SR) 3.8.3.6 from the TS to a licensee-controlled document. SR 3.8.3.6 requires the emergency diesel generator (EDG) fuel oil storage tanks (FOST) to be drained, sediment removed, and cleaned on a 1O-year interval. The request is submitted consistent with the guidance contained in NRC approved Technical Specifications Task Force Report 2 (TSTF-2) (ADAMS Accession No. ML040360147).

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

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StePhe~p. Sands, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-461

Enclosures:

1. Amendment No. 186 to NPF-62

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-461 CLINTON POWER STATION, UNIT NO.1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 186 License No. NPF-62

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Exelon Generation Company, LLC (the licensee), dated September 2,2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regUlations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-62 is hereby amended to read as follows:

-2 (2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment NO.186, are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Russell Gibbs, Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance: Apr i 1 2, 2009

ATTACHMENT TO LICENSE AMENDMENT NO. 186 FACILITY OPERATING LICENSE NO. NPF-62 DOCKET NO. 50-461 Replace the following pages of the Facility Operating License and Appendix "A" Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove License NPF-62 License NPF-62 Page 3 Page 3 TSs TSs 3.8-23 3.8-23

-3 (4) Exelon Generation Company, pursuant to the Act and to 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level Exelon Generation Company is authorized to operate the facility at reactor core power levels not in excess of 3473 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix 8, as revised through Amendment No. 186, are hereby incorporated into this license.

Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Amendment NO.186

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.3.3 Verify fuel oil properties of new and In accordance stored fuel oil are tested in accordance with the Diesel with, and maintained within the limits of, Fuel Oil the Diesel Fuel Oil Testing Program. Testing Program SR 3.8.3.4 Verify each required DG air start receiver 31 days pressure is ~ 200 psig.

SR 3.8.3.5 Check for and remove accumulated water from 92 days each fuel oil storage tank.

CLINTON 3.8-23 Amendment No.186

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• • • • "" SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.186 TO FACILITY OPERATING LICENSE NO. NPF-62 EXELON GENERATION COMPANY, LLC CLINTON POWER STATION, UNIT NO.1 DOCKET NO. 50-461

1.0 INTRODUCTION

By letter dated September 2, 2008 (Agencywide Document Access and Management System (ADAMS) Accession No. ML082470688), AmerGen Energy Company (now known as Exelon Generation Company), the licensee for the Clinton Power Station (CPS), requested to amend the CPS Unit NO.1 Technical Specifications (TS) to relocate the TS surveillance requirement (SR) 3.8.3.6 from the TS to a licensee-controlled document. SR 3.8.3.6 requires the emergency diesel generator (EDG) fuel oil storage tanks (FOST) to be drained, sediment removed, and cleaned on a 1O-year interval. The request is submitted consistent with the guidance contained in Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force Report 2 (TSTF-2) (ADAMS Accession No. ML040360147).

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. These TSs are derived from the plant safety analyses.

In Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR 50.36), the Commission established its regulatory requirements related to the content of the TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls.

As stated in 10 CFR 50.36(c)(2)(i), LCOs are "the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications ... " The remedial actions in the TSs are specified in terms of LCO conditions, required actions, and completion times (CTs), or allowed outage times, to complete the required actions. The conditions and required actions specified in the TSs must be acceptable remedial actions for the LCO not being met, and the CTs must be a reasonable time for completing the required actions while maintaining the safe operation of the plant.

As required by 10 CFR 50.36(c)(3), SRs are the requirements related to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that

-2 facility operation will be within safety limits, and that the LCOs will be met. The staff reviewed the proposed changes for compliance with 10 CFR 50.36 and agree with the precedent as established in NUREG-1433 and NUREG-1434, General Electric Plants. In general, licensees cannot justify TS changes solely on the basis of adopting the model Standard Technical Specifications (STS). To ensure this, the staff makes a determination that proposed changes maintain adequate safety. Changes that result in relaxation (less restrictive condition) of current TS requirements require detailed justification.

Licensees may revise the TSs to adopt improved standard TS format and content provided that plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative, or provides clarification (i.e., no requirements are materially altered); (2) the change is more restrictive than the licensee's current requirement; or (3) the change is less restrictive than the licensee's current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. The detailed application of this general framework, and additional specialized guidance, are discussed in Section 3.0 in the context of specific proposed changes.

3.0 TECHNICAL EVALUATION

In its application, the licensee proposed to relocate SR 3.8.3.6 from TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air." SR 3.8.3.6 requires every 10 years that each EDG FaST is drained of fuel, the accumulated sediment is removed from each tank, and each tank is cleaned. The licensee has proposed to relocate the requirements contained in SR 3.8.3.6 to a licensee controlled document. No other SRs in TS 3.8.3 are being changed by this proposed amendment and there is no change to the frequency of any SRs in TS 3.8.3.

The licensee stated that SR 3.8.3.6 is a preventive maintenance activity and is not needed to demonstrate the operability of the EDGs. Furthermore, the licensee stated that EDG fuel oil will continue to be maintained within the acceptable quantity and quality limits with the relocation of the requirements of SR 3.8.3.6. The NRC staff agrees that SR 3.8.3.6 is a maintenance activity and is not a necessary surveillance to demonstrate the operability of the EDGs and, therefore, does not meet the criteria in 10 CFR 50.36 for retention in TS. Furthermore, NRC has not included the requirements of SR 3.8.3.6 through the incorporation of TSTF-2 in its current revision of the improved STS for boiling-water reactors (BWRs), like the CPS, in NUREG-1433 (BWR/4) and NUREG-1434 (BWR/6).

The licensee stated in the license amendment request that once the SR is removed from TS, the FaST cleaning requirement will be governed by the current CPS commitment to Regulatory Guide (RG) 1.137, "Fuel-Oil Systems for Standby Diesel Generators," Revision 1, dated October 1979 (ADAMS Accession No. ML003740180) as described in the CPS Updated Safety Analysis Report (USAR) Section 1.8. Any changes regarding compliance with the RG will be evaluated pursuant to 10 CFR 50.59, "Changes, Tests, and Experiments." The licensee stated that in removing SR 3.8.3.6 from the TS, the requirement to perform the actions in the current SR will reside in the CPS USAR as a commitment to RG 1.137, Section c.2.f, which specifies that the fuel oil stored in the tanks should be removed, the accumulated sediment removed, and the tanks cleaned at 1O-year intervals. Current SR 3.8.3.6 is based on Section C.2.f of RG 1.137

-3 and compliance with RG 1.137 is addressed in Section 1.8 of the CPS USAR. The licensee stated that CPS will comply with the requirements of RG 1.137, Section C.2.f, without exception.

Any changes to the USAR are performed in accordance with 10 CFR 50.59. NRC staff finds this USAR change mechanism acceptable and, therefore, the relocation of the FOST requirement to the CPS USAR is acceptable.

As stated in 10 CFR 50.36(c)(3), the SRs in a TS are to demonstrate that the LCO in that specification is being met. LCO 3.8.3 requires that the "stored fuel oil, lube oil, and starting air subsystem shall be within limits for each required emergency diesel generator (EDG)." LCO 3.8.3 will continue to be met by the performance of SRs directly related to EDG fuel oil quantity and quality limits to ensure that the EDGs can perform their design safety function.

The three remaining SRs in TS 3.8.3 relative to the stored fuel oil are the following:

1. SR 3.8.3.1 verifies that each fuel oil storage tank contains:

a. 2: 48,000 gal of fuel for EDG 1A;

b. 2: 45,000 gal of fuel for EDG 'I B; and

c. 2: 29,500 gal of fuel for EDG 1C.

2. SR 3.8.3.3 verifies that the fuel oil properties of the new and stored fuel oil are tested in accordance with, and maintained in accordance with the limits of the Diesel Fuel Oil Testing Program, which is TS 5.5.9 of the plant TSs.

3. SR 3.8.3.5 periodically requires checks for, and removal of, any accumulated water from the FOST(s).

SR 3.8.3.1 ensures that the required minimum volume of fuel is present in the tank. SR 3.8.3.3 ensures that the fuel oil is of the necessary quality in accordance with the needed fuel oil properties defined in the Diesel Fuel Oil Testing Program of TS 5.5.9. This program limits the water and sediment content of the fuel oil. SR 3.8.3.5 ensures that the FOSTs are periodically checked for water accumulation and that any accumulated water is removed.

Based on the above evaluation, the NRC staff concludes that SR 3.8.3.6 is not needed to demonstrate that LCO 3.8.3 is being met and, therefore, does not meet 10 CFR 50.36 for inclusion in the plant's TSs. Based on this, the NRC staff concludes that the proposed amendment to relocate the FOST cleaning requirements of SR 3.8.3.6 from the TSs to the CPS USAR and the deletion of SR 3.8.3.6 from TS 3.8.3 is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendment. The State official had had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The NRC staff has determined that the amendment changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR

-4 Part 20, or which changes an inspection or a surveillance requirement. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been public comment on such finding published in the Federal Register on November 4,2008 (73 FR 65687). The amendment was inadvertently published a second time on January 27,2009 (74 FR 4771). There was no change in the proposed finding that the amendments involve no significant hazards consideration.

Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Gerald Waig Kristy Bucholtz Date: Apri 1 2, 2009

April 2, 2009 Mr. Charles G. Pardee President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 SU B..1 ECT: CLINTON POWER STATION, UNIT NO.1 - ISSUANCE OF AMENDMENT RE: LICENSE AMENDMENT REQUEST TO ADOPT TSTF-2, "RELOCATE THE 10-YEAR SEDIMENT CLEANING OF THE FUEL OIL STORAGE TANK TO LICENSEE CONTROL" (TAC NO. MD9589)

Dear Mr. Pardee:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 186 to Facility Operating License No. NPF-62 for the Clinton Power Station (CPS), Unit NO.1. The amendment is in response to your application dated September 2, 2008, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML082470688).

The amendment requested to amend the CPS Unit NO.1 Technical Specifications (TS) to relocate the TS surveillance requirement (SR) 3.8.3.6 from the TS to a licensee-controlled document. SR 3.8.3.6 requires the emergency diesel generator fuel oil storage tanks to be drained, sediment removed, and cleaned on a 10-year interval. The request is submitted consistent with the guidance contained in NRC-approved Technical Specifications Task Force Report 2 (TSTF-2) (ADAMS Accession No. ML040360147).

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, IRA!

Stephen P. Sands, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-461

Enclosures:

1. Amendment No. 186 to NPF-62

2. Safety Evaluation DISTRIBUTION:

PUBLIC LPL3-2 R/F RidsOgcRp Resource RidsNrrLATHarris Resource RidsNrrDirsltsb Resource RidsNrrPMClinton Resource RidsNrrDorlLpl3-2 Resource RidsNrrDorlDpr Resource RidsNrrRgn3MailCenter Resource RidsAcrsAcnw_MailCTR Resource ADAMS Accession No ML090710868 NRR-058 OFFICE LPL3-2/PM LPL3*2!LA DIRS/ITSB OGC(NLO) LPL3-2/BC NAME SSands THarris RElliott MSmith RGibbs DATE 03/25/2009 03/26/2009 02/5/2009 03/24/2009 04/2/2009 OFFICIAL RECORD COpy