RS-14-006, Clinton, Unit 1, Updated Licensing Basis Documents
Text
o4300 Winfield Road AWarrenville, IL 60555 Exeton Generation 630 657 2000 Office 10 CFR 50.4(b)(6) 10 CFR 50.71(e)10 CFR 50.59(d)(2)
RS-14-006 January 9, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461
Subject:
Clinton Updated Licensing Basis Documents In accordance with the requirements of 10 CFR 50.71, "Maintenance of records, making of reports," paragraph (e)(4), Exelon Generation Company, (EGC), LLC submits Revision 16 to the Updated Safety Analysis Report (USAR) for Clinton Power Station.The USAR is being submitted on Optical Storage Media (OSM) in its entirety, including documents incorporated by reference (e.g., Operational Requirements Manual (ORM)).USAR pages changed as a result of this update are delineated with "REV. 16, JANUARY 2014" in the page footer.Changes to the USAR and ORM have been made under the provisions of 10 CFR 50.59,"Changes, tests, and experiments." EGC has evaluated these changes in accordance with 10 CFR 50.59 and concluded that the changes do not require prior NRC approval.Attachment A provides a brief summary of the changes incorporated into USAR Revision 16.Attachment B provides the required summary report pursuant to 10 CFR 50.59(d)(2).
Attachment C contains a summary of regulatory commitment changes.Attachment D summarizes the changes to the ORM.Attachment E contains the directory path, filename, and size of each individual file.
January 9, 2014 U. S. Nuclear Regulatory Commission Page 2 of 2 One DVD is included in this submission.
The DVD labeled, "Exelon Generation Clinton Station USAR Rev. 16 January 2014, ORM" contains the following components:
001 CPS USAR Rev 16.pdf, 730 megabytes (MB), publicly available 002 CPS ORM.pdf, 1.41 megabytes (MB), publicly available As Manager -Licensing, I certify that the information in this submittal accurately presents changes made since the previous submittal necessary to reflect information and analyses submitted to the NRC or prepared pursuant to NRC requirements, and changes made under the provisions of 10 CFR 50.59.There are no commitments made in this document.
Should you have any questions concerning this letter, please contact: Amy Hambly Exelon Nuclear 4300 Warrenville, IL 60555 Phone: (630) 657-2808 E-Mail: amy.hambly@exeloncorp.com Patrick R. Simpson Manager -Licensing Attachments Attachment A, "CPS USAR Revision 16 Change Summary Report" Attachment B, "10 CFR 50.59 Summary Report" Attachment C, "Summary of Regulatory Commitment Changes" Attachment D, "Summary of Operational Requirements Manual Changes" Attachment E, "OSM Directory Structure" cc: Regional Administrator
-NRC Region III NRC Senior Resident Inspector
-Clinton Power Station Attachment A CPS USAR Revision 16 Change Summary Report Page 1 of 2 USAR Change 2011-001, Gas accumulation per GL2008-001.
USAR Section 6.3.2.2.6 added and new references added in Section 6.3.6. This change is required by Clinton Issue Report (IR) 1323285 prior to the Technical Specification change from Technical Specifications Task Force Traveler TSTF-523, which allows ECCS discharge lines to be sufficiently full to accomplish safety function rather than just full. This change provides clarifying information relative to the current status of responses made to Generic Letter 2008-01, Managing Gas Accumulation.
No substantive USAR change can be made without NRC approval of TSTF Traveler TSTF-523.
A final USAR change may be made after TSTF-523 is approved and License Amendment Request (LAR) submitted.
IR 1323285. Editorial Change.USAR Change 2011-011, Digital Feedwater USAR Changes. Various sections under USAR Section 7.7.1.4 revised. Functional descriptions changed for replacement of the analog Feedwater Control System with a digital system. EC 380150. 50.59 Evaluation CL-201 1-E-010.USAR Change 2012-006, Abandon Reactor Water Cleanup Filter Demineralizer Inlet Temperature Switch. USAR Figure 3.6-1 revised and USAR Section 7.7.1.8.3.2 changed to remove the references to the abandoned temperature switch. EC 388796. 50.59 Screen CL-2012-S-01 6.USAR Change 2012-018, Open Reactor Core Isolation Cooling (RCIC) Lube Oil Cooling Valve and Open Breaker to this Valve. USAR Sections 5.4.6.2.2.2, 5.4.6.2.5.1, 7.4.1.1.3.7, 7.4.1.4.4.2, Table 5.4-5 Table 3.9-5, and Appendix F Table 1.8-2 changed to reflect the RCIC lube oil cooling valve is normally open and power is normally removed from this valve with the supply circuit breaker normally open. EC 390555. 50.59 Screen CL-2012-S-034.
USAR Change 2012-020, Add Clarifying Information for Flooding Impact on Fire Pumps.USAR Appendix E, Section 4.0 changed to add clarification regarding flooding criterion used at Clinton where discussing Fire Protection Program Single Failure Criterion compliance with BTP APCSB 9.5-1 Appendix A Section 4.0. IR 1409119. Editorial change.USAR Change 2012-021, Emergency Battery Light Replacements.
USAR Section 9.5.3.1 changed to reflect the approved alternate design of Emergency Battery Lights that may be installed.
EC 387357. NEI 98-03 Guidance.USAR Change 2013-001, Deleted UL 900 Classification.
USAR Sections 6.5.1.2.1, 6.5.1.2.2, 6.5.1.2.3, and Table 6.5-3 changed to reflect Underwriter Laboratories (UL) issuing a revision to the ANSI/UL 900 that removed the Class 1 and Class 2 designations.
Components requiring to meet UL 900 Class 1 or Class 2 are labeled as meeting UL requirements.
EC 390921. NEI 98-03 Guidance.USAR Change 2013-002, Remove Valves from Listing Table 3.9-5. USAR Table 3.9-5 changed to eliminate valves from USAR Table 3.9-5 that have been determined to no longer have an active safety function.
IR 1102406. 50.59 Screen CL-2013-S-002 and Editorial change.
Attachment A CPS USAR Revision 16 Change Summary Report Page 2 of 2 USAR Change 2013-005, New Main Steam Line Plugs. USAR Section 9.1.4.2.5.2, Table 9.1-4, and Table 3.2-1 changed to update Safety Classification and Seismic Category of the new Main Steam Line Plugs. EC 389795. 50.59 Screen CL-2013-S-004.
USAR Change 2013-006, Reflect the Presence of Certain Diesel Oil Instrumentation.
USAR Section 7.3.2.11.1 changed to accurately reflect the presence of temperature alarms that performs temperature monitoring of the fuel oil storage and transfer system. IR 1478342.Editorial change.USAR Chanaqe 2013-008, Provide Reference to Quality Assurance Topical Report (QATR) NO-AA-1 0. USAR Section 13.4 changed to remove excessive details that are covered in the QATR.IR 1445975. NEI 98-03 Guidance.USAR Change 2013-009, Change Wording for Clarification of Refueling Platform and Hoists.USAR Section 7.6.1.1.3.2 and section 9.1.4.3 changed to accurately describe the operation and configuration of Refueling Platform and Hoists. EC 392050 and IR 1496719. 50.59 Screen CL-2013-S-013 and Editorial change.USAR Chan-ge 2013-010.
Allowing Volumetric Examinations (Ultrasonic (UT) or Radiographic (RT)) in Lieu of Radiography Examination.
USAR Section 10.4.4.4 changed to identify Volumetic examination, either UT or RT, allowed for inspecting pipe weld joints. EC 390683.50.59 Screen CL-2013-017.
USAR Change 2013-014, Clinton Loss of Stator Cooling (LOSC) Event. USAR Section 15.2.11 and Section 15.2.12 changed to add discussion of a Loss of Stator Cooling Event. IR 1391534.50.59 Screen CL-2013-S-023.
USAR Change 2013-017, Clarify Secondary Containment Testing. USAR Section 6.2.6.5.3 changed to correctly reference the location of Secondary Containment test description and purpose. Action Request (AR) 734466-24.
NEI 98-03 Guidance.USAR Change 2013-018, Correct a Typographical Error. USAR Sections 9.2.1.2.4, 9.2.5.3, and Table 9.2-14 changed to correctly reference the location of Shutdown Service Water (SX)design basis inlet temperature.
IR 1523792. Editorial change.USAR Change 2013-019, Remove Fuel Pool Cooling and Cleanup Low Suction Pump Trip.USAR Sections 7.6.1.9.4.1, 7.6.1.9.4.2, and 9.1.3.2 changed to reflect plant modification of removing the Spent Fuel Pool Cooling Pumps low suction pressure trip function.
EC 392511.50.59 Evaluation CL-2013-E-001.
USAR Change 2013-020, Clarify the Existence of Several Hatches on SX Pump Structure Roof.USAR Section 2.4.10 and Section 3.4.1.1 changed to correctly identify several hatches are installed on the SX pump structure roof. IR 1429733. Editorial change.
Attachment B 10 CFR 50.59 Summary Report Page 1 of 3 This attachment contains 50.59 evaluation summaries performed for Clinton Power Station (CPS) during this reporting period.Activity Number / Title CL-201 1 -E-01 0, Revision 1: Engineering Change (EC) 380150, Digital Feedwater (DFW)Control Upgrade Description of Activity The scope of this activity is to replace the obsolete Bailey Electronics Reactor Water Level Control System and GE GC-20 Turbine Driven Reactor Feedpump Speed Control System with a new Westinghouse Electric Company (WEC) supplied Ovation digital control system.The DFW system provides several opportunities to eliminate Single Point Vulnerability (SPV)components in the present analog system. These include auctioneered power supplies, fault tolerant digital design, and selected redundant output components.
Reason for Activity The existing Bailey Meter analog card controls are exhibiting the aging of electronic equipment, and are increasingly unavailable in the present market. Additionally, the analog system requires recalibration and tuning adjustments and confirmations during each outage, resulting in both manpower drain and outage schedule impacts to complete if any anomalies or failures are identified.
Also, the existing system and its related transmitter inputs only have a single aging power supply source, which subjects the plant to single failure vulnerability.
Replacement with a digital control system allows the monitoring and calibration to be minimized, and will provide redundancy for both the power supply and the central processor functions, as well as selected inputs and outputs with the replacement digital system. Also, the existing three channel Reactor Water Level -Level 8 independent trip system relaying will be replaced with equivalent relays using the same logic at 24V DC.Bases for Not Requiring Prior NRC Approval A 50.59 Evaluation is required because of the need to consider the changes in the method of controlling the feedwater system with the use of touch screen display control and eliminating of certain individual control switches for starting-stopping pumps, opening-closing valves and resetting trip or test functions.
The Evaluation is also required for conversion of analog controls with individual channels to a redundant digital controller system with input/output (I/O) modules.The Evaluation has also reviewed the changes in design bases and functional responses.
These conditions have been analyzed and determined to be not more than minimally adverse.Based on the 50.59 Evaluation the activity may be implemented per plant procedures without obtaining a License Amendment; because no other increased transient, accident, or malfunctions, consequences, and increased probabilities or likelihood of an accident or malfunction have been identified as more than minimally adverse in the 50.59 review process.Site Plant Operations Review Committee (PORC) approved on April 9, 2013, meeting Number 13-006.
Attachment B 10 CFR 50.59 Summary Report Page 2 of 3 Activity Number / Title CL-2013-E-001:
EC 392511, Fuel Pool Cooling (FC) System Pump Trip Reliability
-Low Suction Pressure Description of Activity The activity removes the low suction pressure trip for FC pumps 1 FC02PA and 1 FC02PB by lifting the leads off of the low suction pressure relay which complete the pump trip logic.Reason for Activity This modification is to remove the asset protection trips of the fuel pool cooling pumps IFC02PA and 1 FC02PB. These trips are being removed to eliminate the risk of an invalid protective trip of the pumps. A review of the plant design has determined that there are no components which could fail in such a way as to defeat the spent fuel pool cooling function with the low suction pressure trips removed. This is considered acceptable as it is balancing the risk of an actual condition which would require a protective action with the risk of an invalid actuation of the pump trip logic, and emphasizes the importance of decay heat removal functions from the various fuel storage pools during all operational modes and the reactor core during refueling modes.Bases for Not Requiring Prior NRC Approval The 50.59 screening determined that the low suction pressure trip is described in the USAR and its removal would be considered adverse. The 50.59 evaluation determined that the low suction pressure trip is not needed to prevent any accident condition or malfunction, and that its removal does not result in an increase in the likelihood of an accident or malfunction, an increase in consequences of an accident or malfunction, or an accident or malfunction with a different result. This was determined based on a review of plant design. This review identified no single active failures which could create a low suction pressure condition.
With no credible failure mode which could create a rapid and sustained low suction pressure condition.
The low suction pressure trip is not required to ensure the FC pumps meet their acceptance criteria as described in section 9.1.3.3.2 of the USAR. As a result, prior NRC approval is not required to perform this activity.
Site PORC approved on June 25, 2013, meeting Number 13-012.
Attachment B 10 CFR 50.59 Summary Report Page 3 of 3 Activity Number I Title CL-2013-E-033:
EC 387251, Computer Code TRACG04P Version 4.2.69.0 for Oscillation Power Range Monitor (OPRM) Setpoint Determination Description of Activity This activity addresses the use of the General Electric Hitachi (GEH) advanced, multi-purpose NSSS thermal-hydraulic transient code TRACG04P, Version 4.2.69.0, for the purpose of determining the Oscillation Power Range Monitor (OPRM) setpoints for Clinton Power Station (CPS). OPRM setpoints are determined for each operating cycle as part of the standard reload licensing process performed in accordance with General Electric's Standard Application for Reactor Fuel (GESTAR II) methodology.
The cycle specific OPRM setpoints are presented in the Core Operating Limits Report (COLR). Version 4.2.69.0 of TRACG04P is an upgraded version of the NRC approved TRACG02A program originally developed and licensed to determine OPRM setpoints.
Version 4.2.69.0 of TRACG04P has not been generically approved by the NRC for OPRM setpoint determination.
OPRM system trip functions are described in the UFSAR and the evaluation of OPRM Period Based Detection Algorithm (PBDA) setpoints is performed as part of the CPS cycle specific safety analysis process. NEDO-32465-A is cited in Technical Specification 3.3.1.3 by reference.
Therefore, use of TRACG04P Version 4.2.69.0 constitutes a change in methodology requiring evaluation in accordance with 10CFR 50.59.Reason for Activity The TRACG04P code has recently been revised by the vendor, GEH, to address a number of programming issues identified since its initial release. The use of TRACG04P version 4.2.69.0 for CPS Delta Critical Power Ratio Over Initial Maximum Critical Power Ratio Verses Oscillation Magnitude (DIVOM) analysis when determining OPRM stability setpoints constitutes a change in methodology.
The upgraded version of the code was developed under the GEH NRC-approved Quality Assurance Program. However, since TRACG04P Version 4.2.69.0 has not been reviewed and approved by NRC for DIVOM analysis, and GEH is not a license holder, the change needs to be evaluated under 10CFR 50.59 by Exelon.Bases for Not Requiring Prior NRC Approval GEH benchmarking analyses confirm that TRACG04P produces DIVOM curves that are slightly conservative (more limiting) than those produced by TRACG02A.
Therefore, the use of TRACG04P Version 4.2.69.0 does not constitute a departure from a method of evaluation described in the USAR and TRACG04P can be used to support the determination of cycle specific OPRM setpoints without prior NRC approval.
Site PORC approved on September 25, 2013, meeting Number 13-021.
Attachment C Summary of Regulatory Commitment Changes Page 1 of 1 There are no Regulatory Commitment Changes for this reporting period.
Attachment D Summary of Operational Requirements Manual Changes Page 1 of 1 The following revision to the Clinton Power Station (CPS) Operational Requirements Manual (ORM) has been made in accordance with approved station procedures.
Changes to the ORM are reviewed per 10 CFR 50.59. This change has been implemented since the submittal of the CPS USAR Revision 15 to the NRC, through December 1, 2013.Revision Scope of Revision Number Revision 76 Section 2.3.2 Structural Integrity.
ORM is reinstated, reinforcing the requirements specified in 10 CFR 50.55a. Reference 50.59 screening CL-2013-S-008.
b.Attachment E OSM Directory Structure Page 1 of 1 All files listed below are* oubliclv available Directory Path File Name.. Size E:\001 CPS USAR Rev 16 000 USAR Cover and LOEP.pdf 425 KB E:\001 CPS USAR Rev 16 001 CH 01 Intro and General Desc.pdf 1173 KB E:\001 CPS USAR Rev 16 002 CH 02 Site Characteristics.pdf 1559 KB E:\001 CPS USAR Rev 16 003 CH 02 Figures Part 1 of 5.pdf 23175 KB E:\001 CPS USAR Rev 16 004 CH 02 Figures Part 2 of 5.pdf 23489 KB E:\001 CPS USAR Rev 16 005 CH 02 Figures Part 3 of 5.pdf 40490 KB E:\001 CPS USAR Rev 16 006 CH 02 Figures Part 4 of 5.pdf 29233 KB E:\001 CPS USAR Rev 16 007 CH 02 Figures Part 5 of 5.pdf 7718 KB E:\001 CPS USAR Rev 16 008 CH 03 Design of Struct Comp Equip.pdf 3946 KB E:\001 CPS USAR Rev 16 009 CH 03 Figures 3.3-1 thru 3.5-6.pdf 1985 KB E:\001 CPS USAR Rev 16 010 CH 03 Figure 3.6-1 Part 1 of 9.pdf 39749 KB E:\001 CPS USAR Rev 16 011 CH 03 Figure 3.6-1 Part 2 of 9.pdf 37239 KB E:\001 CPS USAR Rev 16 012 CH 03 Figure 3.6-1 Part 3 of 9.pdf 45495 KB E:\001 CPS USAR Rev 16 013 CH 03 Figure 3.6-1 Part 4 of 9.pdf 34492 KB E:\001 CPS USAR Rev 16 014 CH 03 Figure 3.6-1 Part 5 of 9.pdf 47837 KB E:\001 CPS USAR Rev 16 015 CH 03 Figure 3.6-1 Part 6 of 9.pdf 29528 KB E:\001 CPS USAR Rev 16 016 CH 03 Figure 3.6-1 Part 7 of 9.pdf 39270 KB E:\001 CPS USAR Rev 16 017 CH 03 Figure 3.6-1 Part 8 of 9.pdf 30180 KB E:\001 CPS USAR Rev 16 018 CH 03 Figure 3.6-1 Part 9 of 9.pdf 37779 KB E:\001 CPS USAR Rev 16 019 CH 03 Figures 3.6-2 thru 3.6-16.pdf 776 KB E:\001 CPS USAR Rev 16 020 CH 03 Figure B3.6 and D3.6 series.pdf 24820 KB E:\001 CPS USAR Rev 16 021 CH 03 Figures 3.7-1 thru 3.11-16.pdf 21745 KB E:\001 CPS USAR Rev 16 022 CH 04 Reactor.pdf 2861 KB E:\001 CPS USAR Rev 16 023 CH 05 RCS and Connect Systems.pdf 2990 KB E:\001 CPS USAR Rev 16 024 CH 06 Engineered Safety Features.pdf 18762 KB E:\001 CPS USAR Rev 16 025 CH 07 Instrument and Control Sys.pdf 6450 KB E:\001 CPS USAR Rev 16 026 CH 08 Electric Power.pdf 1195 KB E:\001 CPS USAR Rev 16 027 CH 09 Auxiliary Systems.pdf 3754 KB E:\001 CPS USAR Rev 16 028 CH 10 Steam and Power Conv.pdf 1008 KB E:\001 CPS USAR Rev 16 029 CH 11 Radioactive Waste Mgmt.pdf 1604 KB E:\001 CPS USAR Rev 16 030 CH 12 Radiation Protection.pdf 2512 KB E:\001 CPS USAR Rev 16 031 CH 13 Conduct of Operations.pdf 600 KB E:\001 CPS USAR Rev 16 032 CH 14 Initial Test Program.pdf 963 KB E:\001 CPS USAR Rev 16 033 CH 15 Accident Analysis.pdf 8283 KB E:\001 CPS USAR Rev 16 034 CH 16 Technical Specifications.pdf 42 KB E:\001 CPS USAR Rev 16 035 CH 17 Quality Assurance.pdf 50 KB E:\001 CPS USAR Rev 16 036 APP A Glossary.pdf 91 KB E:\001 CPS USAR Rev 16 037 APP B Const Mati Stds and QC.pdf 148 KB E:\001 CPS USAR Rev 16 038 APP C Computer Programs.pdf 7112 KB E:\001 CPS USAR Rev 16 039 APP D TMI Requirements.pdf 2385 KB E:\001 CPS USAR Rev 16 040 APP E Fire Protection Report.pdf 1051 KB E:\001 CPS USAR Rev 16 041 APP E Figures Part 1 of 2.pdf 37196 KB E:\001 CPS USAR Rev 16 042 APP E Figures Part 2 of 2.pdf 33701 KB E:\001 CPS USAR Rev 16 043 APP E Figures Cable Tray Dwgs.pdf 49157 KB E:\001 CPS USAR Rev 16 044 APP F Safe Shutdown.pdf 43737 KB E:\002 CPS ORM 001 CPS ORM.pdf 1454 KB