ML22111A190

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Submittal of Revision 22 to Updated Safety Analysis Report, Letter and Attachments A-F
ML22111A190
Person / Time
Site: Clinton Constellation icon.png
Issue date: 03/31/2022
From: Gullott D
Constellation Energy Generation
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML22111A226 List:
References
RS-22-048
Download: ML22111A190 (19)
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~ Constellationo RS-22-048 March 31, 2022 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 4300 Winfield Road Warrenville. IL 60555 630 657 2000 Office 10 CFR 50.4(b)(6) 10 CFR 50.71(e) 10 CFR 50.59(d)(2)

Subject:

Clinton Power Station Updated Safety Analysis Report (USAR), Revision 22 In accordance with the requirements of 1 O CFR 50. 71, "Maintenance of records, making of reports," paragraph (e)(4), Constellation Energy Generation, LLC (CEG) submits Revision 22 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 (Clinton Operational Requirements Manual (ORM) updated through Revision 93, Clinton Technical Specifications Bases. (TSB) updated through Revision 21-11). USAR pages changed as a result of this update are delineated with "Rev. 22, March 2022" in the page footer.

Changes to the USAR, ORM and TSB have been made under the provisions of 10 CFR 50.59, "Changes, tests, and experiments." CEG has evaluated these changes in accordance with 1 O CFR 50.59 and concluded that the changes do not require priorNRC approval.

Attachment A provides a brief summary of the._changes incorporated into USAR Revision 22.

Attachment B provides the required summary report pursuant to_ 1 O CFR 50.59(d)(2).

Attachment C contains a summary of regulatory commitment changes.

Attachment D summarizes the changes to the ORM.

Attachment E provides a required summary report pursuant to 1 O CFR 72.48.

Attachment F contains the directory path, filename, and size of each individual file.

March 31, 2022 U.S. Nuclear Regulatory Commission Page 2 of 2 One (1) OSM is included in this submission. The OSM labeled, "Constellation, Clinton Power Station, USAR Rev. 22, March 2022," contains the following components:

001 CPS USAR Rev 22.pdf, 862 megabytes (MB) 002 CPS ORM.pdf, 1.15 MB 003 CPS TSB.pdf, 1. 79 MB As required by 10 CFR 50.71(e)(2)(i), I certify that to the best of my knowledge, 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 10 CFR 50.59.

There are no new commitments made in this document. Should you have any questions concerning this letter, please contact:

Amy Hambly Constellation Energy Generation, LLC 4300 Warrenville, IL 60555 Phone: (630) 657-2808 E-Mail: amy.hambly@constellation.com Respectfully,

Gullott, David M.

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/\\ Digitally signed by Gullett; David M.

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'D.ate:2022.033113:55:03-0S'OO' c:;.:/,*- _,,

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David M. Gullatt Director - Licensing Constellation Energy Generation, LLC

Enclosure:

OSM-Constellation, Clinton Power Station, USAR Rev. 22, March 2022 Attachments:

Attachment A - CPS USAR Revision 22 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:

NRC Regional Administrator - NRC Region Ill NRC Senior Resident Inspector-Clinton Power Station

USAR. 2019-015 Attachment A CPS USAR Revision 22 Change Summary Report Page 1 of 6 Revise Secondary Containment Tornado Design Criteria and Extend to Fuel Building Railroad Airlock Change pr;ovides additional information. The tornado wind and missile protection requirements for the secondary containm~nt are removed. In addition, the secondary containment is extended to the Fuel Building Railroad Airlock. Table 3.2-1, Section 3.3.2.3, Section 3.5.2.2, Table3.5-5, Section 3.8.4.1, Section 3.8.4.1.2, Section 3.8.4.3, Section 6.2.3, Section 6.2;3.2, Section 6.2.3.3.2.1, Section 6.2.3.3.2.2, Section 6.5:1.1.1, Section 6.5.1.2.1, Figure 6.2-132, Figure 6.4-

3. 50.59 Evaluation CL-E-2019-031.

USAR 2019-018 Update USAR Values for Containment Design Parameters (Upper Pool Makeup Volume)

Change identifies Change Value for "Upper Pool Makeup Volume" from 14,748 ft3 to 14, 736 ft3 in USAR Table 6.2-1 and Table 6.2-4. USAR Table 6.2-1, "Containment Design Parameters;"

USAR Table 6.2-4, "Initial Conditions Employed in Containment Response Analysis (Case 82)"

50.59 Safety Screening CL-2019-S-032.

USAR 2020-002 Implementation of License Amendment No. 226 This change is for the removal of insertions description in systems operation Section 15.4.9.2.2.

USAR 2020-003 IEEE Std 338 Clarification Change adds clarification that IEEE Std 338 App~ndix contents are not requirements. IEEE Std 338-1977: Appendix states, "This appendix is not part of IEEE Std 338-1977" and "this appendix presents a discussion of good practices which are recommended for consideration". Based on this wording, the contents of the Appendix are.not IEEE Std 338 requirements. This is a Non-Regulatory Change.

USAR 2020-005 MCR Habitability Hazardous Chemical Survey Analysis 2019 EC issues calculations for the Hazardous Chemical Survey that is routinely performed every 6 years. Updates to the USAR are for updated survey results. Section 2.2.3.1.3 is updated to remove historical information. The Section 2.2.3.3 is updated to reflect the current revisions of references. Table 2.2-7 is updated and made active to list the relevant hazards based on Reference 14. EC 630055, Calculation VC-94,91-073.

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USAR 2020-007 Attachment A CPS USAR Revision 21 Change Summary Report Page 2 of 6 Turbine Missile Analysis Update Change updates description of turbine missile analysis to incorporate new MPR analysis 0958-0163-CALC-001. Effect of Extending Turbine Valves and Overspeed Protection System Test Intervals on Turbine Missile Generation Probability. Correct formatting on page 3.5-4 (move third paragraph to the left). and corrected Table U-1 to Table U.1 in third paragraph from the.

bottom. Add calc as new Reference 16. Sections 3.5.1.3 (p. 3.5-3 and 3.5-4); 3.5.4 (p. 3.5-18),

MPR analysis 0958-0163-CALC-001. Rev. O and issued under.EC 631000. NU REG 1048 Appendix u. Probability of Missile Generation in GE Nuclear Turbines.

USAR 2020-008 Issue Calculation Incorporating MPR Analysis and USAR Change to Extend PM Frequency of Turbine Control Valves Changes frequency of Turbine Valve exercises will tie governed by CPS PM Program instead of Manufacturer recommendation - See MPR Analysis 0958-0163-CALC-001 as basis for this change. Section 10.2.3.6. EC 631000.

USAR 2020-09 NFPA Code of Record update Change aligns the CPS UFSAR NFPA Codes of Record with the NFPA Code Conformance Evaluation. This is an editorial change that adds all codes that CPS has committed to historically to the UFSAR. Section 9.5-5 and 9.5-6, pages 5244 and 5245.

USAR 2020-011 USAR Table not updated as part of implementation of License Amendment 201 Change updates USAR Table 6.5-3, Section C.4, description of operation of ESF atmosphere cleanup train should be operated from at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month to 15 minutes as required per Tech Specs. USAR Table: 6.5-3, Section C.4.

USAR 2020-013 Remove RCIC from list of Engineered Safety Features in Section 6.0 of CPS USAR Change removes "Reactor Core Isolation Cooiing System" from the list of Engineered Safety Features. Provides a note in Table 6.1-1 such that RCIC is not implied to be an ESF. Section 6.0, Page6.1-1. Table6.1-1, Page6J-9.

USAR 2020-016 Update USAR as part of implementation of License Amendment No.

226 This change is to the RPC *may be bypassed as allowed by TS during shutdown provided coupling of all withdrawn control rods have been verified. This verification ensures that a CRDA cannot occur. Thus, minimizing the worth of control rods to mitigate a CRDA is not required.

USAR 15.4.9.2.2.

USAR 2020-017 Attachment A CPS USAR Revision 21 Change Summary Report Page 3 of 6 Correct typo in USAR Table 6.2-47 USAR Table 6.2-47, "Isolation Valve Summary for Line Penetrating Containment," on Page 6.2-164 has a typo. Containment Penetration No. 20, Valve 1E12F065B should be Valve 1E12F365B. USAR Table 6.2-47.

USAR 2020-018.

Implementation of ANSI/ANS 3.1-2014 to support Fleet Adoption Change removes of ANSI/ANS 3.1-1978 and replacing with ANSI/ANS 3.1-2014.

Updating R.G. 1.8 Revision from 2 to 4.. ORM: 6.5.3.1, USAR Sections: 13.1.2.2.1.3, 13.1.3.1, 13.1.3.2, and 13.2.1.'1, Pages:1.8-6, 1.8-7, 1.8-8, 1.8-9, 1.8-10, 8.3-13.

USAR 2020-019 Clarification for testing frequencies being controlled by the Surveillance Frequency Change Program (SFCP)

Change provides clarification in regards to the testing frequencies being controlled by the Surveillance Frequency Change Program (SFCP). The specific Sections being updated are:

3.9.3.1.1.15 RCIC Turbine which discusses Quarterly Surveillance Testing; 3.9.3.1.1.16 RCIC Pump for quarterly operation test; 7.3.2.1.2.3.1.9 for accuracy checks and transmitters not needing to be valved out of service more than once per operating cycle 7.3.2.1.2.3.1.1 0 for ADS which states transmitters need only be calibrated once per fuel cycle.

USAR 2020-021 ERA T Static Var Compensator (SVC) Long Term Abandonment This Design change package (DCP) 628200 is abandoning the Static Var Compensator (SVC) on Emergency Reserve Auxiliary Transformer (ERAT). Additionally, EC 628200 will install Mechanically Switched Capacitor Control (MSCC) system along with placing ON-LOAD Tap Changer (OLTC) on ERAT in "AUTOn. UFSAR Sections 8.2.2.1, 8.3.1.1.1, 8.3.1.1.2.

USAR 2020-024 r

EC 617767 Upgrade Spent Fuel Pool Gate 1FH04J Seals and Backup Air Supply Change provides description of design basis for spent fuel pool gate 1 FH04J and safety-related backup air supply in$talled per EC617767. Table 3.2-1, Section 3.5.1.1, Section R 1.4.1, Section 9.1.4.3, Section 9.3.1.1.1, Section 9.3.1.2, Section 9.3.1.3, Table 9.3-1, Table 9.3-2.

USAR 2020-029 License Amendment 235 - Emergency Reserve Auxiliary Transformer (ERA Tl Automatic Load Tap Changer fL TC)

Change amends limitation on ERA T L TC mode of operation to allow automatic operation.

Section 8.3.1.1.2, Unit Class 1 E A-C Power System; Page 8.3-6.

USAR 2020-033 Replace the 0FP01PA Centrifugal Fire Pump, Control Panel, Diesel Engine. and Right-Angle Gear Drive Change replaces the 0FP01 PA centrifugal fire pump, control panel, diesel engine, and right-angle gear drive. Section 9.5.1.2.2.3, page 9.5-1 0.

USAR 2020-034 Attachment A CPS USAR Revision 21 Change Summary Report Page 4 of 6 Update UFSAR 7.3.1.1.1.3.6 Bypasses and Interlocks to Reflect EC 633012 Change adds a description of a key lock switch added by EC 633012 that will allow Operations personnel to bypass the 1 E22-F,004 Seal In for the Open and Closed Position as required by EOP-1 A to allow for ~tter Reactor Water Level Control. This will be added to CPS 4411.04 and take the place of previous steps which required that the associated cubicle be de-energized and leads cut to accomplish this outcome. Sections 7.3.1.1.1.3.6, Page 7.3-4 USAR 2020-036.

Add USAR 15.9 to reflect SBO SER (NUREG 0853 Februa!l 1992)

Change adds new section 15.9 and Table 15.9-1, 2, 3, and 4 to the USAR which reflects the NRC approved SBO design and licensing bases as outlined in NUREG 0853 February 1992.

This will include references to the applicable correspondence and capturing the various considerations that were part of the approval process. References to the new USAR section 15.9 are added to USAR Section 1.8 page 1.8-7 4 under Regulatory Guide 1.155 Station Blackout, and the USAR Section 8.3. The Chapter 15 index is updated to reflect the new section and associated tables.

USAR 2021-002 Update UFSAR with OPIS lnformati~n Change updates the UFSAR with more detailed information on the Open Phase Isolation System.to meet industry standards. Section 8.2.1.2 Switchyard, Page 8.2-4.

USAR 2021-004 Update USAR Appendix E Fi.re Protection Drawings for Va1ve Team War Room on RW 762' Change to USAR Appendix E: FP-19a. FP-19b. and Figure 17: Add approximate location and outline of Valve Team War Room. USAR Appendix E: FP-19a. FP-19b, and Rgure 17.

USAR 2021-005 Required USAR Changes based on Relief Request 2205 Change clarifies that 1 0CFR 50.55a(z)1 is also a relief method.to the requirements of 1 0CFR 50.55a(f). Chapter 3 Para 3.9.6, Page 3.9~96.

USAR 2021-006 USAR Markup for Clinton Power Station GNF3 Fuel Introduction These changes are due to new GNF3 nuclear fuel assemblies. Note: USAR Change# 2021-016 will address "MEOD 2.0" after this package. This package includes moving certain Chapter 15 appendices to HISTORICAL consistent with NEI 98-03, as well as minor historical or updating corrections and editorial enhancements. It has been determined that there are no CL 1C21 reload-related USAR changes. EC 630772 Rev, 00, Nuclear Fuel Transition to GNF3 at Clinton Power Station - Operations.

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Attachment A CPS USAR Revision 21 Change Summary Report Page 5 of 6 USAR 2021-008 USAR Markup for New GNF3 Fuel Handling and Receipt This change makes EC 633756 allows the receipt and handling of new unirradiated GNF3 fuel to store in the New Fuel Vault, Spent Fuel Pool, Upper Containment Pool. 3.1.2.6.3.1, 9.1.1.1.3, 9.1.1.2, 9.1.1.3.1, 9.1.2, 9.1.2.1.1.2, 9.1.2.2.1.3, 9.1.2.2.1.4, 9.1.2.2.2.3, 9.1.2.3.1, 9.1.2.3.1.1, 9.1.2.3.1.2, 9.1.2.3: 1.3, 9.1.2.3.1.4, 9.1.6.

USAR 2021-012 Section 9.2.1 Screenwas~ Water*Treatment Changes Change provides updated information to USAR Section 9.2.1.1.1 states that the screenwash discharge water is dechlorinated for NPDES permit compliance, this is no longer required since the sodium hypochloite injection point was moved (rom Plant Service Water (WS) pump suction to WS pump discharge header. Sections 9.2.1.1.3 & 9.2.1.2.2 state that WS pump suctions are treated with sodium hypochlorite, this injection point has been moved to WS pump discharge header. Sections 9.2.1.1.1, page 9.2-1; Section 9.2.1.1.3, Page 9.2-2; Section 9.2.1.2.2, Page 9.2-4.

USAR 2021-014 License Amendment 237 - 50.69 Implementation Change updates the USAR to support implementation of License Amendment 237. USAR Sections: Table of Contents, 3.02, 3.09, 3.1 O, 3.11, 6.2, 6.6.

USAR 2021-016 UFSAR Markup for Clinton Power Station MEOD2.0 (Expanded Maximum Extended Operating Domain)

The changes are due to the new operating domain (with increased core flow window) for Clinton. There are some editorial/clarification 'edits (indicated on table). This package has been prepared to "follow" implementation of GNF3 NFI markup #2021-006, i.e. some of these changes may supersec;te/update USAR changes proposed for GNF3. EC 632262, Rev, 00, Expanded Maximum Extended Operating Domain (MEOD2.0).

USAR 2021-018 Addition of Marathon Ultra MD Blades Description into CPS USAR Change provides-updates the description of the Marathon Ultra MD Blades into the USAR.

Section 4.2.3: add Marathon Ultra MD Pg. 4.2-4: Section 4.2.3, Section 4.2.8: Add Marathon Ultra MD report into References, Pg. 4.2-10: Section 4.2.8.

USAR 2021-019 Revise USAR Section 11.3.2.4.1.1.4 to align with PMMR PMC.;21-130670 Extending VJ. VL VQ and VQ HVAC System Testing PMS PMMR PMC-21-130670 has been created to extend the*current frequency of leakage testing based on good performance of the current equipment. A review of the testing performance has shown exemplary performance and repeatability. As such. an extension to 6Y frequency from

  • 2Y fi:'equency has been processed as allowed by 1 O CFR 50.65(a)(3). Note: While not all the SSCs extended are within the scope of the Maintenance Rule. extending the Pf\\,'ls on these SSCs will allow maintenance to be focused on SSCs that require.it which is the stated intent of the Maintenance Rule. Section.,11.3.2.4.1.1 74..

USAR 2021-023 Attachment A CPS USAR Revision 21 *change Summary Report Page 6 of 6 Section 9.5 Fire Pump Alarm Clarification and NFPA Code Update Change provides updates to the NFPA code year of the installed FP "A" pump as supplied by the vendor, and updates to section 9.5.1.2.2.3 to generalize the specific alarms listed that initiate a common trouble alarm at the central control station. The alarming conditions shall still be required to provide alarm, but this generalizes the specific alarm names. Section 9.5.1.1, NFPA Codes Table (page 9.5-5) and Section 9.5.1.2.2.3 (pages 9.5-10,9.5-11)

USAR 2021-024 UFSAR Markup for Clinton Power Station MEOD2.0 (Expanded Maximum Extended Operating Domain) -R1 Change the MEOD2.0 report 006N3212 is Revision 01 instead of 00 as shown in the USAR package 2021-016. That is the extent of the change. Pg 6.3-42, pg 15.0-14, pg 15.1-14, pg 15.2-36b, pg 15.4-21, pg 15.6-19, pg 150-45, pg 15F-3. EC 632262, Rev, 00, Expanded Maximum Extended Operating Domain (MEOD2.0); 006N3212-R1, Clinton Power Station Maximum Extended O_perating Domain Expansion (MEOD2.0)", GEH Report, October 2021.

USAR 2021-025 Revert Changes made by EC 628233 The NRC has identified a Severity Level IV Non-Cited Violation (NCV) of 10 CFR 50.59(d)(1),

"Changes, Tests, and Experiments/ for 50.59 Evaluation CL-2019-E-031 implemented with EC 628233. See IR 04444504. The changes made by Revision O of EC 628233 are changed back to the previous USAR descriptions. Table 3.2-1, Section 3.3.2.3, Section 3.5.2.2, Table 3.5-5, Section 3.8.4.1, Section 3.8.4.1.2, Secti.on 3.8.4.3, Section 6.2.3, Section 6.2.3.2, Section 6.2.3.3.2.1, Section 6.2.3.3.2.2, Section 6.5.1.1.1, Section 6.5.1.2.1, Figure 6.2-132, Figure 6.4-3 USAR 2021-026 Eliminate Unnecessary Detail on Opening MSIVs Change eliminates unnecessary details on opening MSIV's. Sections 10.3.2.

Attachment B CPS 10 CFR 50.59 Summary Report Page 1 of 6 This attachment contains 50.59 evaluation summaries performed for Clinton Power Station (CPS) during this reporting period.

Activity Number /Title CL-2018-E-007 Abandon PASS Reactor Coolant Sample Line Description of Activity This activity abandons in place primary containment isolatiqn valve (PCIV) 1PS038 (outboard) and removes PCIV 1PS037 (inboard), which are on the PostAccident Sampling System (PASS) reactor coolant sample line. A blind coupling will be installed to isolate this line and aba*ndon this portion of containment penetration 1 MC-21 0. Control power will be removed to the valve actuators, and valve position indication will also be removed at Main Control Room (MCR) panels 1 H13P638/639. Abandonment tags will be hung on 1,PS038, and labels placed on the MCR panels and PASS panel 1 PS03J to indicate that the valves and reactor coolant sample line are abandoned in place/removed.

Reason for Activity There is a history of valve 1 PS037 failing to open. Several design changes have been implemented with different types of valves, but the problem continues. Therefore, the decision was made to abandon the line in place.

Bases for Not Requiring Prior NRC Approval The proposed activity has no adverse impact on the containment isolation function of the line, but does have an adverse impact on the ability to sample reactor water in a post-accident scenario. Abandoning the valves and isolating *the sample line will remove the ability to sample high pressure reactor water following an accident. There is an alternate method to sample reactor water through the RHR A and RHR B pump discharge, which allows the commitment made following License Amendment 155 to maintain contingency plans to sample reactor water post-accident. Though redundancy is reduced, Clinton maintains the ability to sample water from the reactor in a situation post-accident. The proposed activity does not result in more than a minimal increase in the frequency of occurrence of an accident, the likelihood of occurrence of a malfunction, the consequences of an accident, or the consequences of a malfunction.

Activity Number /Title CL-2018-E-008 Power Recovery Via BELSIM Data ~econciliation & Validation (DVR) Methodology Description of Activity This activity provides the basis for accepting the use of the BELSIM software and the Data Validation and Reconciliation (DVR) thermal model of the plant provided by True North. This activity allows the addition of any new procedures, as applicable, and revision of existing

  • procedures that determine and apply a correction factor to the feedwater flow measurement

Attachment B CPS 10 CFR 50.59 Summary Report Page2of6 used to calculate core thermal power. This will change the calculated core thermal power that is used to calibrate the APRMs and ultimately will allow the 'calculated core thermal power to be closer to the actual core thermal power. No physical changes are made to the plant.

Core Thermal Power is currently indicated with the calorimetric heat balance via 3D Monicore and the Plant Process Computer (PPC) at CPS, and can be manually calculated using

  • procedure 2208.01, OD-3, and data recorded in the PPC. The calculation relies on 18 different computer points involving Reactor Pressure, Feedwater Flow, Feedwater Temperature, Reactor Water Cleanup flow, Reactor Water Cleanup Temperature, Control Rod Drive flow, Recirculation Pump Motor Power. Values from the APRMs and Generator Electrical Output are also used to support and validate the results, but are not inputs to the calorimetric heat balance.

An increase in Feedwater flow will increase core reactivity which will result in a higher thermal power. The model developed by True North using the BELSIM software will provide a more comprehensive analysis of plant conditions to determine a feedwater flow fouling correction factor that when applied will result in less uncertainty in the measured feedwater flow values used in the current procedure. The thermal model will use numerous inputs from the plant computer and reconcile the values based on* inputs from other computer points, plant system pressure drops and other inefficiencies modeled in the system.

Reason for Activity EPRI published Evaluation of Data Reconciliation Methods for Power Recovery (3002005345) in July 2015. This r~port documents the evaluation of utilizing Data Reconciliation Methods to reduce the uncertainty in the final feedwater flow measurement and thereby accomplish power recoyery. This report provides the Thermal Performance Engineer with information that can be used to determine if the Data Reconciliation Methods described in the report could be beneficial in a respective plant application. CPS Vi(as the subject of the study. The results of the report indicate that there is a possible power recovery from 8 to 15 MWe.

Bases for Not Requiring Prior NRC Approval This activity provides a new method for determining a feedwater flow correction factor used in the determination of reactor thermal power. The objective is to correct the actual power produced by the reactor while remaining within the current licensing commitments. The methodology used to provide input to the reactor heat balance based on the feedwater flow measurements is not described in the USAR As a result, the introduction of software to correct for bias and report uncertainty in the feedwater flow measurement and determine a feedwater flow correction factor does not involve* an adverse change to an element of a USAR described evaluation methodology, or use of an alternative evaluation methodology, that is used in*

establishing the design bases or used in the safety analyses.

The result of this activity will be a small change in reactor power while remaining within the current licensing commitments: The likelihood of occurrence of accidents or malfunctions*

evaluated in the USAR is already based on the appropriate limiting conditions, such as licensed reactor power. Consequently, a change in reactor power that is still within the limit will not result in a more than a minimal increase in the frequency of occurrence of any accident or malfunction

Attachment B CPS 10 CFR 50.59 Summary Report Page3of6 evaluated in the USAR. Similarly, the dose consequences of accidents and malfunctions

  • evaluated in the USAR are already based on the appropriate limiting conditions, such as maximum neutron flux and licensed reactor power. As a result, the consequences of accidents and malfunctions as evaluated in the USAR are unaffected by this activity. The small change in reactor power and neutron flux resulting from this activity Will remain within the current licensing commitments. Consequently, this change does not create the possibil\\ty of an accident of a different type or with a different result than any previously evaluated in the evaluated in the USAR. Evaluations in the USAR of the design basis limits associated with fission product barriers are also based on the appropriate limiting conditions. This activity does not change those limiting conditions and, consequently, does not result in a design basis limit for a fission product barrier as described in the USAR being exceeded or altered.

Activity Number* /Title CL-2020-E-046 ERA T SVC Long Term Abandonment

  • Description of Activity This ~ctivity.abandons the Static VAR Compensator (SVC) on the Emergency Reserve Auxiliary Transformer (ERA T) and will install mechanically switched capacitor (MSC) banks along with placing the on-load tap changer (OL TC) for the ERA T in "AUTO" to regulate the voltage on Class 1 E buses ( 1 A 1, 1 B 1, and 1 C1 r Currently, the SVC controls the voltage supplied by the ERA T for the downstream Class 1 E equipment to perform its design function. Also, the OL TC currently installed on the ERAT is only operated manually to provide consistent secondary voltage output.
  • The scope of the design change is:

Set the ERAT OL TC in AUTO mode.

  • - Install MSC banks and MSC Control (MSCC) system to provide reactive power support t~. the 4.16 kV BUS of the auxiliary power transformer at the ERA T.

Install an overvoltage protection scheme for the OL TC to de-energize the drive motor assembly of the OL TC prior to exceeding the 30 minute allowable over voltage limit of 4454 V at the associated bus.

Abandon the SVC and the associated control system.

Reason for Activity The CPS ERAT power system SVC has experienced age degradation, increased age-related component malfunctions, and parts obsolescence. Discussions with the original equipment manufacturer have concluded that many components required do r;iot have spare parts available, and some components of the SVC are operating beyond their life expectancy. The activify implements a solutiorJ to eliminate further age-related component failures from the SVC without having to perform a major upgrade. The solution is to utilize an automatic OL TC integral to the corresponding ERAT large power supply transformer for controlling voltage to the station's auxiliary power systems, and when necessary, automatically connect MSC to provide additional voltage support to CPS's connected auxiliary power system.

I I __

Attachment B CPS 10 CFR 50.59 Summary Report Page4of6

'Bases for Not Requiring Prior NRC Approval.

The new integrated system (OLTC/MSCC) will continue to maintain the voltage at the ESF buses within the current design and licensing limits. The over-voltage protection system will prevent the maximum steady state Class 1 E bus voltage from exceeding the design limit of 4300 V and operation above 4300 V but less than 4454 V is allowed for 30 minutes per USAR 8.3.1.1.2. The ERA T OL TC operating in automatic voltage control, in conjunction with MSCs, ensures that a reliable offsite source of power remains available at the associated bus with voltage within acceptable ranges. A failure mode and effects analysis concluded that the probability of the OL TC and MSCG failing in a manner to impact allowable bus voltage is negligible and bounded by the effects of the failure of the current SVC system. The effect of the modified component failure on bus operation following a LOCA or LOOP is the same as the current SVC design. The function and operation of the ERA T and associated buses as described in the USAR remain unchanged. The activity does not alter the function of any safety system and does not degrade or prevent those systems from performing their intended safety function. No new failure modes are'introduced that will result in an accident of a different type.

Activity Number /Title CL-2020-E-112 Clinton Emergency Operating Procedure (EOP) Updates Description of Activity I

  • This activity revises CPS Emergency Operating Procedures (EOPs) based upon the generic Boiling Water Reactor Owners' Group (BWROG) Emergency Procedures Guidelines (EPGs),

Revision 4, issued in June 2018. The EPG/Severe Accident Guidelines (SAG) Revision 4 is divided into six volumes and now addresses emergency response from all five modes of operation. This activity revises the CPS EOPs to implement the Revision 4 changes.

Reason for Activity NUREG-0737, "Clarification of TMI Action Plan Requirements" Item LC.I established a requirement for EOP upgrades that led to the creation of generic EPGs (i.e., BWROG EPG Revision O through Revision 4). NEI 91-04, "Severe Accident Issue Closure Guidelines,"

Revision 1, Section 5 describes the industry initiative for severe accident management which led to the creation of BWROG SAGs. CPS EOPs currently conform to BWROG EPG Revision 3 Guidelines. Industry insights gained in the wake of the Fukushima accident in March 2011 and other improvements have resulted in enhancements to the strategies contained in the EPGs and the BWROG has issued EPG Revision 4 to include changes associated with the accident and other enhancements.

Bases for Not Requiring Prior NRC Approval The changes to procedures developed from EPG Revision 4 to the CPS EOPs provide direction for operator action as the result of transients or accidents. The changes do not cause any transient or accident; therefore, they cannot cause an increase in the frequency of occurrence of

Attachment B CPS 10 CFR 50.59 Summary Report Page 5 of 6 an accident evaluated in the USAR. The ability to bypass interlocks and isolations is shown to not be required unless conditions have placed the unit outside of design basis conditions.

Consequently, the change in these procedures do not result in more than a minimum increase in the frequency of occurrence of a malfunction of an SSC important to safety previously evaluated in the *usAR. The actions taken meet the assumptions in the safety analysis for the limiting small break loss-of-coolant accident (SBLOCA) which occurs at a higher RPV water level than does the analysis. The symptom-based EOPs allow the Operations staff to respond to a variety of events in an effective manner, and will not result in a change to the consequences of a malfunction as the EPG Revision 4 changes are designed to mitigate those malfunctions. The procedure changes are used to respond to accidents but do not create the possibility for accidents* of different types _because the actions are controlled _to be implemented in response to symptoms from the as-found conditions. These actions are designed and validated and cannot create the possibility for an accident of a different type than any previously evaluated in the USAR. The. procedure. changes do not create the possibility of a malfunction of an SSC important to safety with different results, as the operator actions are designed to mitigate events. The procedures developed from EPG Revision 4 seek to limit PCT to 1500°F or less with allowance to rise to 1800°F under certain conditiqns, which is less than the USAR PCT limit of <2200°F. The actions specified are constructed to maintain the fission product barriers and minimize offsite dose rates, incorporating experience from industry events.

Activity Number /Title CL-2021-E-017 Criticality Safety Analyses (CSAs) for Clintori (Holt~c Cale Hl-2033135 and GESTAR)

Description of Activity This activity is a subset activity of the 2021 _ CPS new fuel introduction (NFI) for GNF3 fuel. The NFI is applicable to CPS Unit 1 for powering future reload cycles. The scope of this activity

  • subject to 50.59 evaluation CL-2021-E-017 is the criticality safety analysis (CSA) which covers.

the fuel racks fabricated by NES and Holtec, located in the spent fuel.storage pool and the fuel.

cask_ storage pool. The Holtec CSA is documented in Revision 3 and Revision 4 of design analysis 01 FC41, "Criticality Safety Analysis for Clinton."

Reason for Activity The plant nuclear fuel storage criticality safety design basis is being updated such that it will also cover the storage of new or spent GNF3 fuel in the CPS Unit 1 SFP. This is needed because CPS is changing fuel types to new GNF3 fuel.

Bases for Not Requiring Prior NRC Approval There is a small increase in the in-rack kinf for GNF3 fuel with respect to the design basis fuel in the Holtec CSA main report. The maximum calculat~d reactivity includes a margin for uncertainty in reactivity calculations and in mechanical tolerances, statistically combined, giving assurance that the true keff will be less than 0.95 with a 95% probability at a 95% confidence.

level. The maximum GNF3 fuel reactivity was determined to be less than the regulatory limit of

Attachment B CPS 10 CFR 50.59 Summary Report Page 6 of 6 0.95. The CSAs are not an input to any dose analyses, as a criticality event is not part of the design or licensing basis and is not explicitly evaluated. The changes in the CSAs to accommodate the introduction of GNF3 fuel does not result in a change to the plant that could create a scenario different than has been previously analyzed in the USAR. The potential failures have aiready been established to be minimal, and such failures have already been :

analyzed. GNF3 fuel is the next generation of GE fuel, which has many similarities with GNF2 fuel and other GE fuel types previously used at CPS. The activity does not result in the introduction of new failure modes or changing the result of a specific failure mode that already exists. The changes in design analysis 01 FC41 to accommodate the introduction of GNF3 fuel does not modify any design basis limits for a fission product barrier. Accordingly, this activity does not result in a design basis limit for a fission product barrier as described in the USAR being exceeded or altered.

Activity Number /Title CL-2021-E-020 AST Dose and LOCA Method Change for Clinton GNF3 New Fuel Introduction Description of Activity This activity is an update to the core inventory source term calculations as a result of transitioning fuel types to GNF3 fuel. Additionally, the activity supports the change in methodology associated with the Loss-of Coolant Accident (LOCA) from the SAFER/GESTR-LOCA methodology to the SAFER/PRIME methodology.

Reason for Activity The GNF3 fuel transition is an evolutionary change to the fuel design. The design provides more efficient fuel utilization while continuing to maintain appropriate safety margins. The more efficient design results in a change to the core source term inventory which requires an update to various calculations related to accident dose. This evaluation is performed to show that the increase in dose does not exceed the more than minimal increase for each type of accident at the various boundaries and that the doses remain within the acceptance criteria. The LOCA methodology is being updated from SAFER/GESTR-LOCA to the approved LOCA method, SAFER/PRIME. The change is required as GNF3 fuel design requires use of the PRIME methodology.

Bases for Not Requiring Prior NRC Approval The total effective dose equivalent (TEDE) results for dose-significant accident scenarios have increased slightly at select locations of interest. These increases are no more than minimal and remain within the acceptance criteria. The update to the LOCA methodology from SAFER/GESTR-LOCA to SAFER/PRIME is an acceptable method of evaluation change because the SAFER/PRIME method is an approved methodology and is being implemented within the requirements of the PRIME method approval.

Attachment C CPS Summary of Regulatory Commitment Changes Page 1 of 2 Subiect Change to Commitment for Staged Dosimetry for 858 Fire Brigade Staging Area Located in NTD Building Existing Commitment Description Staged dosimetry, etc. for B-5-8 Fire Brigade Staging Area located in NTD Building 75TLDs 75 PDs (0-1500 mr)

PD Charger Dosimetry Assignment Form Area Change Out Log and Vendor Label List have been revised to ensure replacement dosimetry for TLD changeouts and ensure that this dosimetry will be available for first responders.

Revised Commitment Description Staged dosimetry, etc. for B-5-B Fire Brigade Staging Area located in NTD Building 75 DLRs.

75 Electronic Dosimeters 20 AAA spare batteries Dosimetry Assignment Form

  • Area Change Out Log and Vendor Label List have been revised to ensure replacement
  • dosimetry for DLR changeouts and ensure that this dosimetry will be available for first responders.

Justification DLRs perform the same function as TLDs as they are both.Dosimeters of Legal Record for dose of an indiVidual. Pocket Dosimeters (PDs) and Electronic Dosimeters both give indications of the accumulated dose an induvial has received during their entry into a Radiological Controlled Area. PDs require the use of a charger and "'D" cell batteries to run the charger and Electronic Dosimeters operate off one 11AAA" battery. Additionally. it will save 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of RP resources on calibrations of the PDs.

Subiect One Time Frequency Extension for Testing-Air to Water Heat Exchanger Air Flow Existing Commitment Description CPS 1003.1 O, Appendix R, CM-4 sta!es: ATI 401275.:.04: Air to Water heat exchangers will be f)eriodically tested to measure and verify cooler air flows within design (CM-4 ).

The basis for the frequency of each test will be documented in the preventive maintenance database.

Each Hx inspection frequency will be adjusted individually within the 5-year (plus 25%

grace) limit based on test res1:1Its.

Revised Commitment Description 1 VH07SB (SX Pump Room 1 B Cooler) heat exchanger is included in the GL 89-13 program (see CPS 1003.10 Appendix A). The commitment to inspect 1VH07SB coils 1VH02AA and

Attachment c CPS Summary of Regulatory Commitment Changes Page2of2 1 VH02AB under 157573-02 and 15757 4-02 is being temporarily revised to allow one-time

, inspection frequency extensions from 75 months to 79 months.

Justification The one-time frequency extensions of 157573-02 and 157574-02 are supported by good performance histories of these PMs. The results of the last inspection performances in 2015 identified, via boroscope, minor accumulation of scale along the entire length of the tubes, but no blockage existed. The layer of scale was approximately 2 to 3 mils thick and was smooth with no nodules; chemical cleaning removed 90-95% of the scale. Eddy current testing was also performed and no tubes were identified for plugging. The previous boroscope inspections in 2011 and 2005 also had similar results. A heat exchanger performance test was last performed in July 2020 with satisfactory results. Based on the previous inspection results and satisfactory performance test, there is reasonable assurance that minor scale accumulation is present and will not have a significant adverse impact on the ability of the heat exchanger to perform its function during the 4-month extension interval.

Attachment D CPS Summary of Operational Requirements Manual Changes Page 1 of 1

. There were eight revisions to the Clinton Power station (CPS) Operational Requirements Manual (ORM) that were made during this reporting period.

The current revision of the CPS ORM is Revision 93.

Revision Scope of Revision Number 86 Revised Section 2.2 to change the surveillance interval from 184 days to 24 months for the Channel Functional Test for the Feedwater System/ Main Turbine Trip on reactor vessel water level high (Level 8) to match the loop calibration frequency.

87 Changed test interval froni 7 days to 31 days for Testing Requirement (TR) r 4.5.3.1, which verifies that battery cell parameters meet Table 2.5.3-1 Category A limits.

88 Extended ORM Section 2.2.12 TR 4.2.12.2 frequ~ncy for performing Channel Functional Test from every. 184 days to 12 months to avoid half-trip risk to the plant.

89 Revised Section 2.2 to change test interval for channel calibration from 24 months to 48 months for the lnterme~iate Range Monitor (IRM) Control Rod Block Functions b (upscale trip) and d (downscale trip). Updated ORM 2.3~2 Structural Integrity TR "2.3.3 Operational Requirement 1.3.5" to read "4.3.2" instead of "2.3.3." Revised Section 6.5.3.1 to replace ANSI/ANS 3.1-1978 with NSI/ANS 3.1-2014, and updated reference to Regulatory Guide 1.8 from Revision 2 to 4.

90 Removed-the## from the applicable modes listed for 1E12-F008 and*

1E12-F009 in ORM Attachment 4, page 2. Removed the## note from ORM Attachment 4, page 36. Clarified the Note and Section 3.4 actions to eliminate potential confusion and bring ORM Section 2.4.1 into alignment with LCO Section 3.0.8. Revised Section 2.2.9 to require two moveabl.e and calibrated detectors instead of three.

91 Revised various trip setpoint values in ORM Attachment 2 Table 7, Table 1

17, and Table 5 to accommodate a larger drift value from a longer loop

  • calibration interval. Also revised Table 17 to include nominal mp se'ipoint values for both the open and close LLS.

92 Revised nominal trip setpoint values in ORM Attachment 2 Table 17, for the Reactor Vessel Water Level-Low Low Low, Level 1 Function due to a longer calibration interval for the ATMs and the replacement of transmitters

\\

with a different model. The values in Table 17 for Table 5 Functions 1.a, 2.a, 4.a, and 5.a are changed to show separate values for the model r

1153D8 and 3153ND transmitters.

93 Revised Section 2.5 (4.5.1.b and 4.5.1.b.2) to extend molded case circuit breaker (MCCB) testing frequency from 96 months to 120 months plus 25% grace.

Attachment E CPS 10 CFR 72.48 Summary Report Page 1 of 1 There were no 72.48 evaluations performed for Clinton Power Station (CPS) during this reporting period.

Directory Path 001 CPS USAR REV 22 001 CPS USAR REV 22 001 CPS USAR REV 22

.001 CPS USAR REV 22 002 CPS ORM 003 CPS TSB 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 Figures Part 2 of 2.pdf 005 CH 0.3 Desian of Struct Comp Equip.pdf 006 CH 03 Fiaures Part 1 of 5.pdf 007 CH 03 Figures Part 2 of 5.pdf 008 CH 03 Fiaures Part 3 of 5.pdf 009 CH 03 Figures Part 4 of 5.pdf 01 O CH 03 Fiaures 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 Svs.pdf 015 CH 08 Electric Power.pdf 016 CH 09 Auxiliary Svstems.pdf 017 CH 10 Steam and Power Conv.pdf 018 CH 11 Radioactive Waste Mamt.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 BConst Matl Stds and QC.pdf 027 APP C Computer Programs.pdf 028 APP D TMI Requirements.pdf 029 APP E Fire Protection Report.pdf 030 APP E Figures Part 1 of 2 031 APP E Figures Part 2 of 2 032 APP F Safe Shutdown.pdf 001 CPS ORM.pdf 001 CPS TSB.pdf

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