ML18304A335
| ML18304A335 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 10/24/2018 |
| From: | Imburgia D Exelon Generation Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18304A432 | List: |
| References | |
| RS-18-135 | |
| Download: ML18304A335 (11) | |
Text
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~ Exelon Generation RS-18~135 October 24, 2018 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 1 O CFR 50.4{b)(6) 10 CFR 50.71 (e) 1 O CFR 50.59{d){2)
Subject:
Clinton Power Station Updated Safety Analysis Report (USAR), Revision 20 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 20 to the Updated Safety Analysis Report (USAR) for Clinton Power Station.
The USAA 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. 20, October 2018" in the page footer.
Changes to the USAA and ORM have been made under the provisions of 1 O CFR 50.59, "Changes, tests, and experiments." EGC has evaluated these changes in accordance with 1 O 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 USAA Revision 20.
Attachment B provides the required summary report pursuant to 10 CFR 5d.59{d)(2).
Attachment C contains a summary of regulatory commitment changes.
Attachment D summarizes the changes to the ORM.
Attachment E pr9vides a required summary report pursuant to 1 O CFR 72.48.
Attachment F contains the directory path, filename, and size of each individual file.
October 24, 2018 U. S. Nucle.ar Regulatory Commission Page2 of 2.
One OSM is induded in this submission. The OSM labeled, "Exelon Generation, Clinton Power Station, USAR Revision 20, October 2018," contains the following components:
001 CPS USAR Rev. 20.pdf, 688 megabytes (MB) 002 CPS ORM.pdf, 1.56 MB As required by 1 O CFR 50.71 (e)(2)(i), I certify that to the best of my knowledg~, the information contained in the enclosures and attachments to this letter accurately reflect information and analyses submitted to the NRC or prepared pursuant to NRC requirements, and changes made under the provisions of 1 O CFR 50.'59.
There are no new commitments made in this document. Should you have any questions concerning this letter, please contact:
Amy Hambly Exelon Generation 4300 Warrenville, IL 60555 Phone: (630) 657-2808 E-Mail: amy.hambly@exeloncorp:com Respectfully,
~/h.:rJ_
Dominic M. Imburgia Manager - Licensing Programs
Enclosure:
Attachments:
OSM - Exelon Generation, Clinton Power Station, USAR Revision 20, October 2018 Attachment A, "QPS USAR Revision 20 Change Summary Report" Attachment B, "CPS 1 O CFR 50.59 Summary Report" Attachment C, "CPS Summary of Regulatory Commitment Changes" Attachment D, "CPS Summary of Operational Requirements Manual Changes" Attachment E, "CPS 1 O CFR 72.48 Summary Report" Attachment F, "CPS OSM Directory Structure" cc:
Regional Administrator-NRC Region Ill NRC Senior Resident Inspector-Clinton Power Station
Attachment A CPS USAR Revision 20 Change Summary Report Page 1 of 3 USAR 2013-011. Add Open Phase Relay to 138kV Circuit Switcher Trips This USAR change added "open phase relay" to Section 8.2.1.2 second paragraph identifying the functions tripping the 138kV Circuit Switcher. 1 O CFR 50.59 Evaluation, CL-2013-E-021, Rev. 2 concluded that prior NRG approval is not required.
USAR Change 2016-009. Add Open Phase Relay Description USAR Section 8.3 was revised to add the Open Phase relay description including the present monitoring only function. 1 O CFR 50.59 Evaluation, CL-2013-E-021, Rev. 2 concluded that prior NRG approval was not required.
USAR Change 2016-011. Revision to Spent Fuel Pool Thermal Response for 12 Month Refueling Cycle This USAR Change Package updated the Spent Fuel Pool decay heat load, time to boil, and boil off rate. USAR Section 9.1.3 was affected by this change.
Calculation 01 FC43 Revisions 3 and 4, "Spent Fuel and Cask Storage Pools Re-rack Thermal Hydraulic Analysis," were issued using the ANSI/ANS-5. 1-1979 "Decay Heat Power in Light Water Reactors" methodology to a two-sigma uncertainty, which constitutes an alternate to the ORIGEN2 methodology currently described in the USAR for the spent fuel pool decay heat calculation.This change was evaluated by 1 O CFR 50.59 Evaluation, CL-2017-E-028, which concluded that prior NRG approval was not required.
USAR 2017-013, Alternate Power for Instrument Air Isolation Valves USAR Table 6.2-47 was revised to reflect the change in closing times for containment instrument air isolation valves from 36 seconds to 20 seconds from the initiating a valve closure signal. This is the result of an enhancement to the reliability of the instrument air power supply. The 1 O CFR 50.59 Screen CL-2017-S-031 concluded that prior NRG approval was not required.
USAR 2017-016, Remove Excessive Detail from Ultimate Heat Sink USAR Sections In USAR Sections 2.4, 9.2 and Table 9.2 this change removed excessive detail that should not be in the USAR. Editorial changes were made to improve readability. This change provides clarifying information a non-regulatory change in accordance with NEI 98-03 guidance.
USAR 2017-020, Mitigation Actions for MS Lines Due to NER-NC-017-007-Y USAR Figures 3.6 -1, Sheet 7 of 111 was revised to remove valve/piping taps within the Main Steam system that have been identified as susceptible to steam leaks. This effort mitigates the consequences of potential steam leaks. In accordance with the Design Equivalent Change and IP-ENG-001, a 50.59 Screen was not required and prior NRG approval for this activity was not necessary.
USAR 2017-022, Add Appropriate Damping Values to Figures 3.7-40 to 3.7-47 and 3.7-83 to 3.7-94 This USAR change add appropriate damping values to Figures 3.7-40 to 3.7-47 and 3.7-83 to 3.7-94. This change provided clarifying information and is a non-regulatory change in accordance with NEI 98-03 guidance. This change is associated with IR 03950267.
USAR 2017-023, Mitigation Actions for Reactor Recirc Lines Due to NER-NC-017-007-Y USAR Figure 3.6-1, Sheet 57 of 111 was revised to reflect the removal of small bore valves/piping taps within the Reactor Recirculation System identified as susceptible to steam leaks. This was a Design Equivalent Change Package, therefore; a 10 CFR 50.59 screening was not required.
Attachment A CPS USAR Revision 20 Change Summary Report Page 2 of 3 USAR 2018-001, Update UHS Analyses (MAD 86-337, Etc.)
This change updates and supplements USAR 2017-016. USAR Sections 1.1, 2.4, and 9.2 were updated to clarify information associated with the Ultimate Heat Sink. Examples include changing the lake surface area from "4895" to "approximately 4900" and removing excessive detail from the USAR. These changes are associated with EC 621780, "Update Ultimate Heat Sink Analyses (MAD 86-337, Etc.)". 10 CFR 50.59 screen CL-2017-S-045 concluded that prior NRG approval was not required.
USAR 2018-002, Fuel Building Crane Rail Evaluation This change adds clarification regarding the jurisdictional boundary between USAR Section 9.1.4.2.2.2 and USAR Section 3.8.4.5 requirements associated with the fuel building crane rail.
The jurisdictional boundaries indicated in this markup are consistent with USAR Revision 19 and the requirements of NUREG-0554. The change clarifies the USAR that the rails, rail clips, and rail clip to girder bolts are part of the crane and it restores Figure 3.8-35. The 10 CFR 50.59 Screen CL-2018-S-003 concludes that prior NRG approval is no required.
USAR 2018-003, Bypass SJAE 2nd Stage Low Steam Flow Switches to Keep 1st Stage SJAE Suction Valve 1 CA002A/B from Automatically Tripping Closed on Low Steam Dilution Flow USAR Sects. 7.7, 10.4, 11.3 and Table 11.3-5 were revised to reflect the removal of the automatic isolation of the condenser from the Steam Jet Air Ejectors (SJAE) on low steam dilution flow by removing auto close feature of 1st stage SJAE suction valve. Jumpers are installed to bypass dilution flow switches. This will require operator action to close isolation valve 1 CA002A/B on low steam dilution flow. 10 CFR 50.59 Evaluation CL-2018-E-006 concluded that prior NRG approval was not required.
USAR 2018-004, Abandon 1 PS037/1 PS038 and Isolate Penetration 1MC-210003 This cont iguration change removed 1 PS037 and abandon 1 PS038/042 in place. A blind coupling will be installed to isolate this line and abandon this portion of containment penetration 1MC-210.
Control power will be removed to the valve actuators and valve position indication will also be removed both at Main Control Room panel 1 H 13P638/639 and at the PASS Panel 1 PS03J. The 10 CFR 50.59 Evaluation CL-2017-E-007 concluded the change does not require prior NRG approval.
USAR 2018-006, Clinton Reload 18/ Cycle 19 USAR Updates USAR Sections 4.1, 15.4, and 15D were revised to bring the USAR into alignment with the new revision of GESTAR which analyzes plastic, creep, and elastic strain depending on peak pellet exposure. Changes to USAR Section 15.D and 15F were made to account for how this cycle's event were analyzed in the SRLR. Changes to USAR Section 15.4 were also made to correct outdated information. The Design Equivalent Change concluded that a 50.59 review and prior NRG approval for this change is not required.
USAR 2018-010, Slip-on Flange on 1RH19BB-4 inch USAR Figures 3.6-1, Sheet 63 and 6.2-147, Sheet 2 were revised to show flanges added to RHR "B" min flow line per slip-on flange on 1RH19BB-4". Portions of lines 1RH19BA-4" and 1RH19BB-4" are being replaced. For ease of pipe replacement, slip-on flanges will be installed on 1RH19BB-4". The Design Equivalent Change concluded that a 50.59 review and prior NRG approval for this change is not required.
Attachment A CPS USAR Revision 20 Change Summary Report Page 3 of 3 USAR 2018-016, Update USAR Text that refer to Previously Deleted References USAR Sections 3.11, 5.2, 5.4, 6.2, 6.3, 7.1, 7.2, 7.3, 7.4, 7.6, 7.7, 9.3, 9.4, 9.5, 10.2, and Appendix D were corrected to remove incorrect references to USAR Sections and update text that referred to previously deleted references. These are non-regulatory changes in accordance with NEI 98-03 guidance.
USAR 2018-017, Correction of Typos and Non-Technical Errors Identified in the USAR USAR Sections 1.10, 7.7.1.9.5.2.1.2, and Table 6.2 were revised to correct typographical and non-technical errors. These are non-regulatory changes in accordance with NEI 98-03 guidance.
USAR 2018-021, Incorporate Information from Previously Approved USAR Change Package 2013-015 USAR Sections 9.1.2.3 and 9.1.4.2.2.2 are revised to include editorial changes which were delineated in EC 392606 Revision 3, for the "ISFSI - Upgrade Fuel Building Crane per Specification K-10064" modification. These changes were required by previously approved USAR Change Package 2013-015 but were inadvertently omitted during the updating of USAR Revision
l CPS 1 O CFR 50.59 Summary Report Page 1 of 2 This attachment contains 50.59 evaluation summaries performed for Clinton Power Station (CPS) during this reporting period.
Activity Number I Title CL-2017-E-028: Revision to Spent fuel Pool Thermal Response for 12 Month Operation Description of Activity This activity issued calculation 01 FC43 Revisions 3 and 4, Spent Fuel and Cask Storage Pools Re-rack Thermal Hydraulic Analysis, using the ANSI/ANS-5.1-1979 "Decay Heat Power in Light Water Reactors" methodology to a two-sigma uncertainty, which constitutes an alternate lo the ORIGEN2 methodology currently described in the USAR for the spent fuel pool decay heal calculation.
Reason for Activity CPS transitioned from 24 months fuel cycles to 12 month fuel cycles which changed the decay heat remaining in the fuel bundled when removed from the core for storage in the Spent Fuel Pool (SFP). Revision 3 to Calculation 01 FC43 quantifies the change in decay heat on the expected SFP temperature to assure that the maximum temperature remains within design limits. Revision 4 to Calculation 01 FC43 determined the effect of this water volume change on the expected SFP temperature. The results of the design analysis 01 FC43 are used as inputs to calculation 01 FC25, IP-M-0746, INSCC004, and VF-54, so these analyses required revision to incorporate the results.
Bases for Not Requiring Prior NRG Approval Based on the previous approval of the use of ANSI/ ANS 5.1-1979 to a two-sigma uncertainty for spent fuel pool decay heat calculations for LaSalle County Station, using this methodology for Clinton Station spent fuel pool decay heat calculations is acceptable and does not result in a departure from a method of evaluation described in the USAR used in establishing the design bases or in the safety analyses. Prior NRG approval for this change was not required.
Activity Number / Title CL-2017-E-042: EC 619869, Install jumper to keep solenoid valve 1 FSVCA002 energized to prevent closure of valve 1 CA002B due to steam flow fluctuations Description of Activity This activity allowed the installation of a jumper into the circuitry which monitors steam flow for the Steam Jet Air Ejector (SJAE) 'B' second stage ejector. Currently, the circuit monitors 2nd stage SJAE Steam Flow and will cause SJAE Suction Valves 1 CA002B to automatically close on low steam flow through the system..
Reason for Activity IR 4069016 identified annunciator window 5130-4E for SJAE process flow high. Trends show a spike up to 121 scfm, a spike down to 95 scfm and a return to 104 scfm and has remained stable.
To prevent the dilution steam flow from dropping to the tripping set point of 76% during power manipulations, a jumper was installed to prevent closure of SJAE inlet valve 1 CA002B by bypassing redundant flow switches 1 B21 N545 and 1 B21 N549 and keep SJAE B suction valve solenoid IFSVCA002 energized.
Bases for Not Requiring Prior NRG Approval Installing a jumper to inhibit automatic isolation of the SJAE dilution steam flow did not introduce the possibility of a new accident because the event associated with this function (ignition of hydrogen due to excessive accumulation in the process flow piping) did not constitute a new or more consequential failure mode. It also does not result in a change that would cause any system parameter to change. Therefore, prior NRG approval is not required.
Activity Number / Title CPS 10 CFR 50.59 Summary Report Page 2 of 2 CL-2018-E-006, Bypass SJAE 2nd Stage Low Steam Flow Switches to Keep 1st Stage SJAE Suction Valve 1 CA002A/B from Tripping Closed on Low Flow Description of Activity This EC removes the automatic trip of the 1st Stage SJAE suction valve from the main condenser on low steam dilution flow to the 2nd Stage SJAE. This was done by bypassing flow switches 1 B21 N546/1 B21 N550 and 1 B21 N545/1 B21 N549 that sense dilution steam flow and consequently trip suction valves 1 CA002A/B on low flow setpoint. During normal operations, steam flow is maintained at 7600 lbm/hr and the low flow isolation causes closure of the suction valve at 76%
steam flow, which isolates offgas flow and can lead to a plant shutdown.
Reason for Activity Documented issues with SJAE train process flow cycling has resulted in unexpected alarms and unit shutdown. This parameter has a history of issues with oscillations during power transients. IR 04069016 documents three MCR alarms from SJAE process flow high in two months. In all cases, there was a transient above the high setpoint followed by a drop-in flow indication before stabilizing, and that similar alerts as well occurred on SJAE A train. IR 0163844 documents a manual scram due to a loss of vacuum which resulted from unstable pressure control of SJAE B.
Due to the risk of a turbine trip caused by this high process flow, condition temp-mod EC 619869 was created to install a jumper that keeps SJAE B 1st Stage suction valve 1 CA200B open if the B train high process low flow alarm occurs. Due to fluctuating steam flow indication and concerns regarding spurious unnecessary isolation during power reductions, this trip circuit wiring will be removed and bypassed to prevent this isolation.
Bases for Not Requiring Prior NRC Approval Removing the automatic closure feature of the SJAE 1st Stage Suction Valve due to dilution steam flow does not result in a change that would cause any system parameter to change.
Implementing this activity does not result in a Design Basis Limit for a Fission Product Barrier (DBLFPB) as described in the UFSAR being exceeded or altered. In addition, removing the automatic closure feature of the SJAE 1st Stage Suction Valve due to dilution steam flow does not introduce the possibility for a malfunction of an SSC with a different result because the activity does not introduce a failure mode that is not bounded by those described in the system description in UFSAR Section 15.
Attachment C CPS Summary of Regulatory Commitment Changes Page 1 of 1 Subject GL 90-03, Relaxation of Staff Position in GL 83-28 Item 2.2 "Vendor Interface for Safety-Related Components" Existing Commitment Description Clinton Power Station committed to a re-contacting frequency of every three years for both suppliers of Safety Related equipment and Nuclear Steam Supply System (NSSS).
Revised Commitment Description In coordination with Exelon Corporation, CPS will discontinue the program of periodic contact for both supplier of Safety Related equipment and Nuclear Steam Supply System (NSSS).
Justification for Deletion The periodic re-contacting of vendors is redundant. The reliability of all equipment at Clinton including safety related and non-safety related components is assured by preventative maintenance and performance monitoring actions implemented after the commitments made in response to these two NRG Generic Letters. The preventative maintenance tasks, frequencies, and detailed actions are subject to continuous improvement and monitoring for effectiveness. This Commitment Change was made under Commitment Change Tracking# 2017-001.
Attachment D CPS Summary of Operational Requirements Manual Changes Page 1 of 1 There were three revisions to the Clinton Power Station (CPS) Operational Requirements Manual (ORM) have been made during this reporting period.
The current revision of the CPS ORM is Revision 83, as reported in Letter RS-16-196 dated October 24, 2016.
Revision Number Scope of Revision 81 Revision to Section 1.0 to align with CPS License Amendment 213.
82 Revision to Attachment 4 to reflects the removal of 1 PS037 and abandonment of 1 PS038/042 in place. This change aligns with the USAR Change Package 2018-004 discussed in Attachment A of this letter.
83 Revision to Attachment 4 to reflect revised valve closing times of instrument air valves which result from modification to provide more reliable power to instrument air valves. USAR Change Package 2017-013 identified revisions to USAR Table 6.2-47 and ORM Attachment 4 that would reflect the above modification. Revision to ORM Sections 1, 2.2, 2.3, 2.4.and 2.5 to correct the inconsistent use of the term "OPERABLE".
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Attachment E CPS 10 CFR 72.48 Summary Report Page 1 of 1 There were no 1 O CFR 72.48 evaluations performed since the previous reporting period.
Directory Path 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 001 CPS USAR Rev 20 002 CPS ORM Attachment F CPS OSM Directory Structure Page 1 of 1 File Name 000 USAR Cover and LOEP.pdf 001 CH 01 Intro and General Desc.pdf 002 CH 02 Site Characteristics.pdf 003 CH 02 Figures Part 1 of 2.pdf 004 CH 02 Fiqures Part 2 of 2.pdf 005 CH 03 Design of Struct Comp Equip.pdf 006 CH 03 Fiqures Part 1 of 5.pdf 007 CH 03 Fiqures Part 2 of 5.pdf 008 CH 03 Figures Part 3 of 5.pdf 009 CH 03 Figures Part 4 of 5.pdf 01 O CH 03 Fiqures Part 5 of 5.pdf.
011 CH 04 Reactor.pdf 012 CH 05 RCS and Connect Systems.pdf 013 CH 06 Engineered Safety Features.pdf 014 CH 07 Instrument and Control Sys.pdf 015 CH 08 Electric Power.pdf 016 CH 09 Auxiliary Systems.pdf 017 CH 1 O Steam and Power Conv.pdf 018 CH 11 Radioactive Waste Mgmt.pdf 019 CH 12 Radiation Protection.pdf 020 CH 13 Conduct of Operations.pdf 021 CH 14 Initial Test Program.pdf 022 CH 15 Accident Analysis.pdf 023 CH 16 Technical Specifications.pdf 024 CH 17 Quality Assurance.pdf 025 APP A Glossary.pdf 026 APP B Const Matl Stds and QC.pdf 027 APP C Computer Proqrams.pdf 028 APP D TMI Requirements.pdf 029 APP E Fire Protection Report.pdf 030 APP F Safe Shutdown.pdf 001 CPS ORM.pdf Size 393 KB 768 KB 1474 KB 85267 KB 33952 KB 2650 KB 41994 KB 77531 KB 82828 KB 69264 KB 98189 KB 2838 KB 2981 KB 20692 KB 6096 KB 1205 KB 4993 KB 1286 KB 911 KB 2485 KB 617 KB 955 KB 13988 KB 40 KB 42 KB 79 KB 125 KB 7091 KB 1964 KB 99397 KB 43387 KB 1599 KB