ML112231943
| ML112231943 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 10/04/2011 |
| From: | Nicholas Difrancesco Plant Licensing Branch III |
| To: | Pacilio M Exelon Generation Co |
| DiFrancesco N, NRR/DORL/LPL3-2, 415-1115 | |
| References | |
| TAC ME4850, TSTF-501 | |
| Download: ML112231943 (18) | |
Text
\.~",R REG V / _ UNITED STATES
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Mr. Michael J. Pacilio 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: REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE (TSTF) TRAVELER TSTF-501, REVISION 1, RELOCATE STORED FUEL OIL AND LUBE OIL VALUES TO LICENSEE CONTROL (TAC NO. ME4850)
Dear Mr. Pacilio:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No.196 to Facility Operating License No. NPF-62 for the Clinton Power Station, Unit NO.1. The amendment is in response to your application dated October 8, 2010, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102810654), as supplemented by letters dated January 6, February 24, and March 8, 2011 (ADAMS Accession Nos. ML110060809, ML110550579, and ML110670305, respectively).
The amendment requested a revision to Technical Specification (TS) 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," by relocating the current stored diesel fuel oil, and lube oil numerical volume requirements from the TS to the TS Bases consistent with TSTF-501 with deviations.
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.
Nicholas J. DiFrancesco, 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. 196 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. 196 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 October 8, 2010 as supplemented by letters dated January 6, February 24, and March 8, 2011, 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;
- 8. 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. 196, 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 60 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION aJJ~ ----
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Ja b I. Zimm man, Chief PI t Licensin 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: October 4, 2011
ATTACHMENT TO LICENSE AMENDMENT NO. 196 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 3.8-20 3.8-20 3.8-21 3.8-21 3.8-22 3.8-22
- 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; (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.
Mechanical disassembly of the GE14i isotope test assemblies containing Cobalt-60 is not considered separation; and (7) Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30, to intentionally produce, possess, receive, transfer, and use Cobalt-60.
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. 196, 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. 196
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).
APPLICABILITY: When associated DG is required to be OPERABLE.
ACTIONS
- ----------- -NOTE---------
Separate Condition entry is allowed for each DG.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more DGs with A.I Restore fuel oil level 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> fuel oil level less to within limits.
than a 7 day supply and greater than or equal to a 6 day supply.
(continued)
CLINTON 3.8 20 Amendment N0'196
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. One or more DGs with B.1 Restore lube oil 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> lube oil inventory less inventory to within than a 7 day supply and limits.
greater than or equal to a 6 day supply.
C. One or more DGs with C.1 Restore fuel oil 7 days stored fuel oil total total to particulates not within limit.
within limit.
D. One or more DGs with D.1 Restore stored fuel 30 days new fuel oil oil properties to properties not within within limits.
limits.
E. One or more DGs with E.1 Restore air 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> required air receiver pressure to receiver pressure ~ 200 psig.
< 200 and
~ 140 psig.
(continued)
CLINTON 3.8-21 Amendment N0'196
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME F. Required Actions and F.1 Declare associated DG Immediately associated Completion inoperable.
Time not met.
OR One or more DGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, D, or E.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains In accordance 2 a 7 day supply of fuel. with the Surveillance Frequency Control Program SR 3.8.3.2 Verify lube oil inventory is 2 a 7 day In accordance supply for each diesel engine. with the Surveillance Frequency Control Program (continued)
CLINTON 3.8-22 Amendment No. 196
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1.0 INTRODUCTION
By letter to the U.S. Nuclear Regulatory Commission (NRC, the Commission) dated October 8, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102810654), as supplemented by letters dated January 6, February 24, and March 8,2011, (ADAMS Accession Nos. ML110060809, ML110550579, and ML110670305, respectively).
Exelon Generation Company, LLC (EGC, the licensee) requested NRC approval on changes to the technical specifications (TSs) for Clinton Power Station (CPS), Unit No.1. The proposed changes would adopt Technical Specifications Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF-501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control," with deviations discussed in Section 3.0.
References 2, 3, and 4 contained clarifying information and did not change the NRC staff's initial proposed finding of no significant hazards consideration.
2.0 REGULATORY EVALUATION
2.1 Modification to LCO 3.8.3, "Diesel Fuel Oil. Lube Oil. and Starting Air," Requirements The regulation at Title 10 of the Code of Federal Regulations (10 CFR) 50.36( c)(2)(i) states TS will include Limiting Conditions for Operation (LCO) which are "the lowest functional capability or performance levels of equipment required for safe operation of the facility."
The standby alternating current (AC) power sources are a part of the primary success path and function or actuate to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Diesel fuel oil and lube oil are retained in the TS to satisfy 10 CFR 50.36( c)(2)(i) since they support the operation of the standby AC power sources. The proposed changes revise TS 3.8.3 by relocating the current stored diesel fuel oil and lube oil numerical volume requirements from the TS to the TS Bases so that they may be modified under licensee control.
The TS 3.8.3 is modified so that the stored diesel fuel oil and lube oil inventories will require that a 7-day supply be available for each DG. As discussed in Section 3.0 of this SE, this change still provides assurance that the lowest functional capability or performance levels of equipment required for safe operation of the facility will continue to be met. The proposed changes meet 10 CFR 50.36(c)(2)(i) and are, therefore, acceptable.
-2 2.2 Modification to Action Table for TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air" Paragraph 50.36(c)(2)(i) goes on to state that "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 until the condition can be met." Condition A and Condition B in the Action table for TS 3.8.3 are revised to reflect the change in LCD requirements as discussed in Section 2.1 above. Currently, Condition A or Condition Bare entered when the stored diesel fuel oil volume or lube oil volume numerical requirements is not met. As discussed in the current TS Bases, the numerical volume requirements in Condition A (fuel oil) and Condition B (lube oil) are based on volumes less than a 7-day supply, but greater than an a 6-day supply. The proposal relocates the volumetric requirements from the TS and places them in the TS Bases. The TS is modified so that Condition A or Condition B are entered when the stored diesel fuel oil or lube oil inventory is less than a 7-day supply, but greater than a 6-day supply for one or more DGs. These remedial actions are permitted by 10 CFR 50.36(c){2)(i), and the technical justification for allowing these remedial actions is discussed in Section 3.0 of this SE.
2.3 Modification to SR 3.8.3.1 and SR 3.8.3.2 Paragraph 50.36{c)(3) states that the TS will include SRs which are "requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." Currently, SR 3.8.3.1 and SR 3.8.3.2 verify that the stored diesel fuel oil and lube oil numerical volume requirements are met. SR 3.8.3.1 and SR 3.8.3.2 are revised to reflect the change in LCD requirements as discussed in Section 2.1 above. As a result, the SRs are modified so that SR 3.8.3.1 and SR 3.8.3.2 verify that the stored diesel fuel oil and lube oil inventories are greater than or equal to a 7-day supply for each DG. As discussed in Section 3.0 of this SE, this change still provides assurance that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The proposed changes meet 10 CFR 50.36(c)(3) and are, therefore, acceptable.
2.4 Deletion of Reference to Append ix B of AN SIN 195-1976 As discussed in Section 2.1 above, LCD 3.8.3 is retained in the TS in order to satisfy 10 CFR 50.36(c)(2)(i). The proposed change deletes the reference to Appendix B of ANSI N195-1976 in the TS Bases for TS 3.8.3. As a result, there will only be a reference to ANSI N195-1976. Although not a part of TS, the TS Bases contain amplifying and clarifying information on TS, and modification of the TS Bases can potentially impact TS requirements.
This modification was evaluated in order to consider the potential change to LCD requirements associated with TS 3.8.3. As discussed in Section 3.0 of this SE, this change still provides assurance that the lowest functional capability or performance levels of equipment required for safe operation of the facility will be continued to be met. The proposed changes meet 10 FR 50.36(c)(2)(i) and are, therefore, acceptable.
-3
3.0 TECHNICAL EVALUATION
=
Background===
By letter dated October 8, 2010, the licensee proposed two deviations from the TS changes described in TSTF-501, Revision 1, and the NRC staffs model safety evaluation (SE) published in the Federal Register (75 FR 29588; May 26, 2010) as part of the consolidated line item improvement process (CLlIP) Notice of Availability. First, the model SE describes the two calculation methods for determining sufficient volumes of stored fuel oil for onsite standby diesel generators (DGs) in accordance with Regulatory Guide (RG) 1.137, "Fuel-Oil Systems for Standby Diesel Generators." These two calculation methods are: (1) determine the volume of fuel oil required to supply power to the DG's time-dependent loads for seven days with an additional volume margin of 10 percent, or (2) determine the volume of fuel oil required to operate the DG at its rated capacity for seven days. In contrast, the CPS Diesel Fuel Oil Storage and Transfer System is designed to provide sufficient storage and supply capabilities of diesel fuel oil to ensure operation of the emergency DGs for a minimum of seven days at maximum post-Ioss-of-coolant accident (LOCA) load demands as discussed in CPS updated safety analysis report (USAR).
Section 9.5.4, "Diesel Fuel Oil Storage and Transfer System." Consequently, the 7-day and 6-day fuel oil volume requirements for the CPS DGs were determined by applying the fuel oil consumption rates while each DG is providing its associated maximum post-LOCA load demands. CPS identified this as a minor variation from the RG 1.137 calculation methods discussed in the model SE. Second, when fuel oils from the spectrum of American Petroleum Institute (API) gravities allowed by CPS TS 5.5.9, "Diesel Fuel Oil Testing Program," were considered in fuel oil consumption calculations for the Divisions 1, 2, and 3 DGs, it was determined that 7-day and 6-day volume requirements listed in TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," for the Division 1 DG were non-conservative. The current volume requirements for the Divisions 2 and 3 DGs remain conservative. Administrative controls are in place at CPS to address the TS 3.8.3 non-conservatism in accordance with NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety." However, in order to rectify this non-conservatism, a revision to the numerical volume requirements for the Division 1 DG was required.
The licensee was requested to provide additional information concerning the above described TSTF-501 deviations. By letters dated January 6, February 24, and March 8, 2011 (Reference 2, 3, and 4, respectively), the licensee provided the requested information. The NRC staff evaluation of the two requested deviations is discussed in Section 3, Technical Evaluation, of this SE.
The proposed changes revise TS 3.8.3 by relocating the current stored diesel fuel oil volume and lube oil volume numerical requirements from the TS to the TS Bases so that they may be modified under licensee control. The TS are modified so that the stored diesel fuel oil and lube oil inventories will require that a 7-day supply be available for each DG. As a result:
-4
- Condition A and Condition B in the Action table are revised. Currently, Condition A and Condition B are entered when the stored diesel fuel oil volume and lube oil volume numerical requirements are not met. As discussed in the current TS Bases, the numerical diesel fuel oil volume requirement in Condition A is based on a volume of less than a 7-day supply, but greater than an a 6-day supply. The numerical diesel lube oil volume requirement in Condition B is based on a volume of less than a 7-day supply, but greater than a 6-day supply. The revision relocates the numerical requirements from the TS and places them in the TS Bases. The TS are modified so that Condition A is entered when the stored diesel fuel oil is less than a 7-day supply, but greater than a 6 day fuel oil supply for one or more DGs. Condition B is entered when stored diesel lube oil is less that a 7-day supply, but greater than a 6-day lube oil supply for one or more DGs.
- Surveillance Requirements (SR) 3.8.3.1 and 3.8.3.2 are revised. Currently, SR 3.8.3.1 and SR 3.8.3.2 verify that the stored diesel fuel oil volume and lube oil volume numerical requirements are met. As discussed in the current TS Bases, the numerical requirements in SR 3.8.3.1 and SR 3.8.3.2 are based on maintaining at least a 7-day supply. The revision relocates the volume numerical requirements from the TS and places it in the TS Bases. The TS are modified so that SR 3.8.3.1 and SR 3.8.3.2 verify that the stored diesel fuel oil and lube oil inventories are greater than or equal to a 7-day supply for each DG. The reference to Appendix B of American National Standards Institute (ANSI) N195-1976, "Fuel Oil Systems for Standby Diesel- Generators," in the TS Bases is deleted. As a result, the only reference will be to ANSI N195-1976.
In its letter dated October 8,2010, the licensee stated that the LAR is consistent with NRC approved TSTF-501, Revision 1 with the deviations noted above. The availability of this TS improvement was announced in the Federal Register on May 26, 2010 (75 FR 29588) as part of the CLlIP.
3.1 Modification to LCO 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," Requirements Each DG is provided with a fuel oil capacity sufficient to operate that diesel for a period of 7 days while the DG is supplying maximum load demand. This onsite fuel oil capacity is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources.
The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated DG under all loading conditions. The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. Each DG has a lube oil inventory capable of supporting a minimum of 7 days of operation. This supply is sufficient to allow the operator to replenish lube oil from outside sources.
In order to meet a 7-day supply of stored diesel fuel oil and lube oil for each DG. TS 3.8.3 currently contains numerical volume requirements associated with a 7-day supply for each DG as measured in gallons. The TS Bases currently discuss that the numerical volume requirements are based on meeting a 7-day supply. The proposed change revises TS 3.8.3 by relocating the current stored diesel fuel oil and lube oil numerical volume requirements from the
-5 TS to the TS Bases so that they may be modified under licensee control. The TS is modified so that the stored diesel fuel oil and lube oil inventories will require that a 7-day supply be available for each DG. No changes to the current plant configuration, current numerical volume requirements, or current 7-day basis are proposed in the application; the licensee is merely relocating the current numerical volume requirements from the TS to the TS Bases and relocating the associated current 7-day basis from the TS Bases to the TS. This change meets the requirements of 10 CFR 50.36 and is, therefore, acceptable.
3.2 Modification to Action Table for TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air" Currently, Condition A or Condition B is entered when the stored diesel fuel oil or lube oil numerical volume requirements are not met. As discussed in the current TS Bases, the numerical volume requirements in Condition A and Condition B are based on volumes less than a 7-day supply, but greater than a 6-day fuel oil supply. The proposal relocates the volumetric requirements from the TS and places them in the TS Bases. The TS are modified so that Condition A or Condition B are entered when the stored diesel fuel oil or lube oil inventory is less than a 7-day supply. but greater than a 6-day supply for one or more DGs.
No other parts of Condition A and Condition B (i.e., Required Actions or Completion Times) are proposed to be modified in the application; the licensee is removing the current numerical volume requirements that dictate Condition entry from the TS to the TS Bases and relocating the associated current less than 7-day but greater than 6-day fuel and lube oil supply from the TS Bases to the TS.
Section 3.3 below discusses the methodology on how the stored diesel fuel oil and lube oil numerical volume basis in the TS Bases may be modified under licensee control. The use of this methodology will ensure that the 7-day and 6-day supply of stored diesel fuel oil and lube oil for each DG, that dictate Condition entry, will continue to be calculated in accordance with NRC-approved methods. This change meets the requirements of 10 CFR 50.36 and is, therefore, acceptable.
3.3 Modification to SRs 3.8.3.1 and 3.8.3.2 Currently, SR 3.8.3.1 and SR 3.8.3.2 verify that the stored diesel fuel oil and lube oil numerical volume requirements are met. SR 3.8.3.1 and SR 3.8.3.2 are revised to reflect the change in LCO requirements, namely that a 7-day supply be available for each DG. As a result, the SRs are modified so that SR 3.8.3.1 and SR 3.8.3.2 verify that the stored diesel fuel oil and lube oil inventories are greater than or equal to a 7-day supply for each DG.
No other parts of the SRs (i.e., Frequencies) are proposed to be modified in the application; the licensee is merely relocating the current numerical volume requirement verification from the TS to the TS Bases and relocating the associated current 7 -day basis for verification from the TS Bases to the TS.
The NRC staff approved TSTF-501 methodology for determining the 7-day stored diesel fuel oil supply for each DG, as well as the 6-day supply associated with Condition A, is calculated in accordance with RG 1.137, Revision 1, and ANSI N195-1976. ANSI N195-1976 discusses how the stored diesel fuel oil requirement shall be calculated based upon the DGs operating at the minimum required capacity for the plant condition which is most limiting for the calculation of such capacity.
-6 The licensee proposes a deviation from the two calculation methods for determining sufficient volumes of stored fuel oil for on-site standby DGs described in RG 1.137, Revision 1. The two RG 1.137, Revision 1, calculation methods are: (1) determine the volume of fuel oil required to supply power to the DG's time-dependent loads for seven days with an additional volume margin of 10 percent, or (2) determine the volume of fuel oil required to operate the DG at its rated capacity for seven days. In contrast, the CPS Diesel Fuel Oil Storage and Transfer System is designed to provide sufficient storage and supply capabilities of diesel fuel oil to ensure operation of the DGs for a minimum of seven days at maximum post-LOCA load demands as discussed in CPS USAR, Section 9.5.4, "Diesel Fuel Oil Storage and Transfer System." Therefore, the proposed 7-day and 6-day fuel oil volume requirements for the CPS DGs were determined by applying the fuel oil consumption rates while each DG is providing its associated maximum post-LOCA load demands.
Additionally, when the licensee considered fuel oils from the spectrum of API gravities allowed by CPS TS 5.5.9, "Diesel Fuel Oil Testing Program," in fuel oil consumption calculations for the Division 1, Division 2, and Division 3 DGs, it was determined that 7-day and 6-day volume requirements listed in TS 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," for the Division 1 DG were non-conservative. The current volume requirements for the Division 2 and Division 3 DGs remain conservative. Administrative controls are in place at CPS to address the TS 3.8.3 non conservatism in accordance with NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety." Therefore, in order to rectify this non-conservative TS, the licensee proposes a revision to the numerical fuel oil volume requirements for the Division 1 DG.
To calculate the 7-day and 6-day supplies of fuel oil for the DGs, the licensee postulated three scenarios for the 7-day period following a worst-case accident loss of offsite power (LOOP)/LOCA. The licensee took the maximum post-LOCA load demand for each DG and applied it for the entire 7-day and 6-day periods. For fuel oil consumption by the DGs, the licensee used consumption rates that are based on the vendor guaranteed rates of consumption. These consumption rates are higher than the consumption rates that the licensee measured during pre-operation testing, so they are conservative. The licensee's range of acceptable API gravities for fuel oil is 30 to 38. The licensee's fuel oil supply calculations use an API gravity of 38, which has the lowest heat content in their acceptable range, which is conservative.
The licensee provided a table showing the quantities for a 7-day supply of fuel oil for each DG based on the ANSI N195-1976 time-dependent method (which includes allowances for fuel consumption required by periodic testing and a 10 percent margin, as well as, volume for vortexing in the storage tank) and the licensee's method described above. For all three DGs, the quantities of fuel calculated by the licensee's method are greater than the quantities calculated by the ANSI N195-1976 method. The quantities calculated by the licensee's method are conservative, therefore, they are acceptable. They are also acceptable for the licensee's calculated 6-day fuel oil supplies. One variable used in both stored diesel fuel oil calculation methods is the fuel consumption rate.
The property of diesel fuel oil having the most Significant effect on the fuel consumption rate is the energy content (heating value) of the fuel. There are standards which correlate the energy content to the fuel's API gravity or absolute specific gravity. At a minimum, plants calculate their required fuel storage values assuming the most limiting API gravity or absolute specific gravity, and therefore, the most limiting fuel energy content. As long as the fuel oil placed in the storage
- 7 tank is within the API gravity range or absolute specific gravity range specified by the licensee, the calculations of fuel consumption and required stored volume remain valid. Current SR 3.8.3.3 requires new fuel to be tested in order to verify that the new fuel API gravity or absolute specific gravity is within the range assumed in the diesel fuel oil consumption calculations.
The lube oil inventory equivalent to a 7-day supply, as well as the 6-day supply associated with Condition B, is based on the DG manufacturer consumption values for the run time of the DG.
The above methods still provide assurance that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. The change to SR 3.8.3.1 and SR 3.8.3.2 meets the requirements of 10 CFR 50.36, and is, therefore, acceptable.
3.4 Deletion of Reference to Appendix B of ANSI N195-1976 The proposed change deletes the reference to Appendix B of ANSI N195-1976 in the TS Bases for TS 3.8.3. As a result, there will only be a reference to ANSI N 195-1976. This modification was evaluated in order to consider the potential change to LCO requirements associated with TS 3.8.3. LCO 3.8.3 requires, in part, that the stored diesel fuel oil and lube oil shall be within limits for each required DG. The basis for these limits is derived from RG 1.137, Revision 1, and Appendix B of ANSI N 195-1976.
For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. RG 1.137, Revision 1, addresses the recommended fuel oil practices as supplemented by ANSI N195-1976, Appendix B. The fuel oil properties that are checked to ensure the proper quality of the fuel oil are sediment content, the kinematic viscosity, specific gravity (or API gravity), and impurity level.
Although the reference to Appendix B of ANSI N 195-1976 will be deleted, RG 1.137, Revision 1, which is currently referenced in the TS Bases, states, "Appendix B to ANSI N195-1976 addresses the recommended fuel oil practices. Although not a mandatory part of the standard, the NRC staff believes Appendix B can serve as an acceptable basis for a program to maintain the quality of fuel oil, as supplemented by regulatory position 2 of this guide." Regulatory Position 2 of RG 1.137 states, in part, Appendix B to ANSI N 195-1976 should be used as a II basis for a program to ensure the initial and continuing quality of fuel oiL" As a result, the use of Appendix B of ANSI N195-1976, as referenced by RG 1.137, still provides a basis for ensuring the proper quality of the fuel oil; namely that water and sediment content, the kinematic viscosity specific gravity (or API gravity), and impurity level are within the specified limits. Current SR 3.8.3.3 verifies these limits.
The change still provides assurance that the lowest functional capability or performance levels of equipment required for safe operation of the facility will continue to be met. Therefore, this modification to LCO 3.8.3 is acceptable.
3.5 Summary and Conclusion The NRC staff has reviewed the licensee's proposed TS changes for compliance with 10 CFR 50.36 and finds that the licensee has adequately evaluated the impact of the proposed modifications. On the basis of its review, the NRC staff concludes that the proposed TS
- 8 changes to relocate stored fuel oil and lube oil volume values to licensee control complies with 10 CFR 50.36. Therefore, the NRC staff finds the TS changes are 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 no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes requirements with respect to installation or use of a facility's components located within the restricted area as defined in 10 CFR Part 20. 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 no public comment on such finding (76 FR 6833; February 8,2011). 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.
7.0 REFERENCES
- 1. Letter from J. L. Hansen (Exelon) to NRC, "License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control letter," dated October 8, 2010. (ADAMS Accession No. ML102810654)
- 2. Letter from J.L. Hansen (Exelon) to NRC, "Response to Request for Additional Information Regarding License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, "Relocate Stored Fuel Oil and Lube Oil Volume values to Licensee Control," dated January 6,2011. (ADAMS Accession No. ML110060809)
- 3. Letter from J.L. Hansen (Exelon) to NRC, "Additional Information Related to License Amendment Request for Adoption of Technical Specifications Task Force 501 ," dated February 24, 2011. (ADAMS Accession No. ML110550579)
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- 4. Letter from J.L. Hansen (Exelon) to NRC, "Supplemental Information Related to License Amendment Request for Adoption of Technical Specifications Task Force-501 ," dated March 8, 2011 (ADAMS Accession No. ML110670305)
- 5. TSTF Traveler 501, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control," Revision 1 , (ADAMS Accession No. ML090510686)
- 6. TSTF-501- Federal Register, Notice of Availability published on May 26,2010 (75 FR 29588).
Principal Contributors: Gerald Waig, NRRlDIRS Robert Wolfgang, NRRlDCI Date of issuance: October 4, 2011
October 4, 2011 Mr. Michael J. Pacilio 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: REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE (TSTF) TRAVELER TSTF-501, REVISION 1, RELOCATE STORED FUEL OIL AND LUBE OIL VALUES TO LICENSEE CONTROL (TAC NO. ME4850)
Dear Mr. Pacilio:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No.196 to Facility Operating License No. NPF-62 for the Clinton Power Station, Unit No.1. The amendment is in response to your application dated October 8,2010, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102810654), as supplemented by letters dated January 6, February 24, and March 8, 2011 (ADAMS Accession Nos. ML110060809, ML110550579, and ML110670305, respectively).
The amendment requested a revision to Technical Specification (TS) 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," by relocating the current stored diesel fuel oil, and lube oil numerical volume requirements from the TS to the TS Bases consistent with TSTF-501 with deviations.
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!
Nicholas J. DiFrancesco, 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. 196 to NPF-62
- 2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL3*2 R/F RidsOgcRp Resource RidsNrrLASRohrer Resource RidsNrrDirsltsb Resource RidsNrrPMClinton Resource RidsNrrDorlLpl3-2 Resource RidsNrrDorlDpr Resource RidsNrrRgn3MailCenter Resource RidsAcrsAcnw_MailCTR Resource ADAMS Accession No. ML112231943 OFFICE LPL3-21PM LPL3-2/PM LPL3-2/LA DIRS/ITSB OGC(NLO w/edits) LPL3-2/BC NAME BHarris NDiFrancesco SRohrer RElliott MMarsh JZimmerman DATE 9126/11 9/23/11 9/26/11 8123111 9/02/11 10104/11 OFFICIAL RECORD COpy