ML23284A251
| ML23284A251 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/22/2023 |
| From: | Joel Wiebe Plant Licensing Branch III |
| To: | Rhoades D Constellation Energy Generation |
| Wiebe J | |
| References | |
| EPID L-2026-LLA-0007 | |
| Download: ML23284A251 (1) | |
Text
November 22, 2023
Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
CLINTON POWER STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT NO. 250 RE: ADOPTION OF TSTF-332 (EPID L-2023-LLA-0007)
Dear Mr. Rhoades:
The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 250 to Facility Operating License No. NPF-62 for the Clinton Power Station, Unit No. 1. The amendment is in response to your application dated January 13, 2023.
The amendment adopts Technical Specifications Task Force (TSTF) traveler TSTF-332-A, Revision 1, ECCS [Emergency Core Cooling System] Response Time Testing. TSTF-332 revises technical specification definitions for ECCS response time, isolation system response time, and reactor protection system response time that are referenced in surveillance requirements (SRs).
A copy of the Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions next monthly Federal Register notice.
Sincerely,
/RA/
Joel S. Wiebe, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket No. 50-461
Enclosures:
- 1. Amendment No. 250 to NPF-62
- 2. Safety Evaluation
cc: Listserv CONSTELLATION ENERGY GENERATION, LLC
DOCKET NO. 50-461
CLINTON POWER STATION, UNIT NO. 1
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No. 250 License No. NPF-62
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found th at:
A. The application for amendment by Constellation Energy Generation, LLC (the licensee), dated January 13, 2023, complies with the standa rds and requirements of the Ato mic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chap ter I;
B. The facility will operate in conformity with the application, the provision s 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 healt h and safety of the public, and (ii) that such activities will be conducted in compliance with th e Commissions regulations;
D. The issuance of this amendment will not be inimical to the common defen se and security or to the health and safety of the public; and
E. The issuance of this amendment is i n accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
Enclosure 1
- 2 -
- 2. Accordingly, the license is amended by changes to the Technical Specif ications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-62 is her eby amended to read as follows:
(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. 250, are hereby incorporated in the license. Constellation Energy Generation, 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
Jeffrey A. Whited, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Facility Operating License and Technical Specifications
Date of Issuance: November 22, 2023 ATTACHMENT TO LICENSE AMENDMENT NO. 250
FACILITY OPERATING LICENSE NO. NPF-62
CLINTON POWER STATION, UNIT NO. 1
DOCKET NO. 50-461
Replace the following pages of the Facility Operating License No. NPF-62 and the 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 INSERT
Page 3 Page 3
Technical Specifications
REMOVE INSERT 1.0-3 1.0-3 1.0-4 1.0-4 1.0-5 1.0-5 1.0-6 1.0-6 3.3-6 3.3-6 3.3-54 3.3-54 3.5-6 3.5-6
(4) Constellation Energy Generation, 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 nucle ar material as sealed neutron source s for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and a s fission detectors in amounts as required;
(5) Constellation Energy Generation, pursuant to the Act and 1 0 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as require d any byproduct, source or special nuclear material without restri ction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparat us or components;
(6) Constellation Energy Generation, pursuant to the Act and 1 0 CFR Parts 30, 40, and 70, to possess, but not separate, such bypr oduct and special nuclear materials as may be produced by the operation of the facility. Mechanical disassembly of the GE14i isotope test a ssemblies containing Cobalt-60 is not considered separation ; and
(7) Constellation Energy Generation, pursuant to the Act and 1 0 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 condition s specified in the Commissions regulations set forth in 10 CFR Chapter I and is su bject to all applicable provisions of the Act and to the rules, regulations and orde rs of the Commission now or hereafter in effect; and is subject to the additional co nditions specified or incorporated below:
(1) Maximum Power Level
Constellation Energy Generation is authorized to operate the facilit y at reactor core power levels not in excess of 3473 megawatts thermal (100 percent rated power) in accordance with the condition s specified herein.
(2) Technical Specifications and Environmental Protection Plan
The Technical Specifications contained in Appendix A and th e Environmental Protection Plan contained in Appendix B, as re vised through Amendment No. 250, are hereby incorporated into t his license.
Constellation Energy Generation shall operate the facility in accordance with the Technical Specifications an d the Environmental Protection Plan.
Amendment No. 250 Definitions 1.1
1.1 Definitions (continued)
CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.
DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same inhalation CEDE dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The inhalation CEDE dose conversion factors used for this calculation shall be those listed in Table 2.1 of Federal Guidance Report 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion," ORNL, 1989.
DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:
- a. The water inventory above the TAF is divided by the limiting drain rate;
- b. The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure for all penetration flow paths below the TAF except:
- 1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;
- 2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or (continued)
CLINTON 1.0-3 Amendment No. 25040 Definitions 1.1
Definitions
DRAIN TIME 3. Penetration flow paths with isolation (continued) devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation devices without offsite power.
- c. The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;
- d. No additional draining events occur; and
- e. Realistic cross-sectional areas and drain rates are used.
A bounding DRAIN TIME may be used in lieu of a calculated value.
EMERGENCY CORE COOLING The ECCS RESPONSE TIME shall be that time interval SYSTEM (ECCS) RESPONSE from when the monitored parameter exceeds its ECCS TIME initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.
END OF CYCLE The EOC-RPT SYSTEM RESPONSE TIME shall be that RECIRCULATION PUMP TRIP time interval from initial movement of the (EOC-RPT) SYSTEM RESPONSE associated turbine stop valve or turbine TIME control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.
(continued)
CLINTON 1.0-4 Amendment No. 25040 Definitions 1.1
1.1 Definitions (continued)
INSERVICE TESTING The INSERVICE TESTING PROGRAM is the licensee PROGRAM program that fulfills the requirements of 10 CFR 50.55a(f).
ISOLATION SYSTEM The ISOLATION SYSTEM RESPONSE TIME shall be that RESPONSE TIME time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.
LEAKAGE LEAKAGE shall be:
- a. IdentifiedLEAKAGE
- 1. LEAKAGE into the drywell such as that from pump seals or valve packing, that is captured and conducted to a sump or collecting tank; or
- 2. LEAKAGE into the drywell atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems;
- b. UnidentifiedLEAKAGE All LEAKAGE into the drywell that is not identified LEAKAGE;
- c. TotalLEAKAGE Sum of the identified and unidentified LEAKAGE; and
LEAKAGE through a fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.
LINEAR HEAT GENERATION The LHGR shall be the heat generation rate per RATE (LHGR) unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length.
(continued)
CLINTON 1.0-5 Amendment No.225042 Definitions 1.1
1.1 Definitions (continued)
LOGIC SYSTEM FUNCTIONAL A LOGIC SYSTEM FUNCTIONAL TEST shall be a test TEST of all logic components required for OPERABILITY of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.
MINIMUM CRITICAL POWER The MCPR shall be the smallest critical power RATIO (MCPR) ratio (CPR) that exists in the core for each class of fuel. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.
MODE A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.
OPERABLE OPERABILITY A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).
RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of 3473 MWt.
REACTOR PROTECTION The RPS RESPONSE TIME shall be that time interval SYSTEM (RPS) RESPONSE from when the monitored parameter exceeds its RPS TIME trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.
(continued)
CLINTON 1.0-6 Amendment No. 25029 RPS Instrumentation 3.3.1.1
SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY
SR 3.3.1.1.16 Verify Turbine Stop Valve Closure and In accordance Turbine Control Valve Fast Closure Trip with the Oil Pressure-Low Functions are not Surveillance bypassed when THERMAL POWER is > 33.3% Frequency RTP. Control Program
SR 3.3.1.1.17 -------------------NOTE-------------------
Neutron detectors are excluded.
Verify the RPS RESPONSE TIME is within In accordance limits. with the Surveillance Frequency Control Program
CLINTON 3.3-6 Amendment No. 250192 Primary Containment and Drywell Isolation Instrumentation 3.3.6.1
SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY
SR 3.3.6.1.3 Calibrate the analog trip module. In accordance with the Surveillance Frequency Control Program
SR 3.3.6.1.4 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program
SR 3.3.6.1.5 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program
SR 3.3.6.1.6 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program
SR 3.3.6.1.7 Verify the ISOLATION SYSTEM RESPONSE In accordance TIME for the main steam isolation valves with the is within limits. Surveillance Frequency Control Program
SR 3.3.6.1.8 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program
CLINTON 3.3-54 Amendment No. 25038 ECCS Operating 3.5.1
SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY
SR 3.5.1.5 -------------------NOTE--------------------
Vessel injection/spray may be excluded.
Verify each ECCS injection/spray subsystem In accordance actuates on an actual or simulated with the automatic initiation signal, except for Surveillance valves that are locked, sealed, or Frequency otherwise secured in the actuated position. Control Program
SR 3.5.1.6 -------------------NOTE--------------------
Valve actuation may be excluded.
Verify the ADS actuates on an actual or In accordance simulated automatic initiation signal. with the Surveillance Frequency Control Program
SR 3.5.1.7 -------------------NOTE--------------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
Verify each ADS valve actuator strokes when In accordance manually actuated. with the Surveillance Frequency Control Program
SR 3.5.1.8 Verify the ECCS RESPONSE TIME for each ECCS In accordance injection/spray subsystem is within limits. with the Surveillance Frequency Control Program
CLINTON 3.5-6 Amendment No. 2504 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO. 250 TO
FACILITY OPERATING LICENSE NO. NPF-62
CONSTELLATION ENERGY GENERATION, LLC
CLINTON POWER STATION, UNIT NO. 1
DOCKET NO. 50-461
1.0 INTRODUCTION
By letter to the U.S. Nuclear Regulatory Commission (NRC, the Commission) dated January 13, 2023 (Agencywide Documents Access and Managem ent System (ADAMS) Accession No. ML23013A180), Constellation Energy Generation, LLC (Constellation, the licensee) requested changes to the technical specifications (TSs), facility operating license, and surveillance requirements (SRs) for Clinton Power Station, Unit No. 1 (Clinton).
The proposed amendment would revise TS definitions for emergency core cooling system (ECCS) response time, isolation system response time, and reactor protection system (RPS) response time that are referenced in SRs, hereafter referred to as response time testing (RTT).
The changes are consistent with Technical Specifications Task Force (TSTF) traveler TSTF-332-A, Revision 1, ECCS Response Time Testing, (ML003751434). Additionally, the licensee also identified proposed variations that would move certain notes in individual RTT SRs to the TS bases.
2.0 REGULATORY EVALUATION
2.1 Regulatory Requirements
The regulation at Title 10 of the Code of Federal Regulations (10 CFR) 50.36, Technical specifications, provides the regulatory requirements for the content of the TSs and requires, in part, that a summary statement of the bases for such specifications shall be included by applicants for a license authorizing operation of a production or utilization facility. Specifically, paragraph 10 CFR 50.36(c)(3), Surveillance requirements, states, that SRs 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 (LCO) will be met.
Enclosure 2
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2.2 Guidance
Though TSTF-332 was developed based on changes to Revision 1 of NUREG-1434, Standard Technical Specifications for General Electric BWR [Boiling-Water Reactor]/6 Plants, the NRC staffs review of the licensees letter dated January 13, 2023, includes consideration of whether the proposed changes are consistent with the latest revision, published in September 2021.
NUREG-1434, Revision 5 (ML21271A582), provi des example TS LCOs and acceptable remedial actions that meet the requirements in 10 CFR 50.36(c)(2)(i) for a standard plant design.
Topical report NEDO-32291-A, System Analysis for the Elimination of Selected Response Time Testing Requirements, dated October 1995 (not publicly available) and Supplement 1 to NEDO-32291-A, dated October 1999 (ML993350325), eliminate the required measurement of certain sensor response times. The NRC staff safety evaluation reports dated December 28,1994, and June 11, 1999, approved NEDO-32291 and Supplement 1, respectively.
NRC Bulletin 90-01, Loss of Fill-Oil in Transmitters Manufactured by Rosemount, and Supplement 1 to Bulletin 90-01 (ML031290411 and ML082490332, respectively) requests that holders of operating licenses or construction permits for nuclear power reactors promptly identify and take appropriate corrective action for certain Rosemount transmitters that may be leaking fill-oil.
3.0 TECHNICAL EVALUATION
3.1 Description of Response Time Testing (RTT)
The RPS initiates a unit shutdown, based on the values of selected unit parameters, to protect against violating the core fuel design limits and the reactor coolant system pressure boundary during anticipated operational occurrences and to assist the engineering safety feature actuation system (ESFAS) in mitigating accidents. The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the reactor coolant system pressure boundary, and to mitigate accidents.
RTT verifies that the individual channel or train actuation response times are less than or equal to the maximum values assumed in the accident analyses. The RTT acceptance criteria are under licensee control. Individual component response times are not modeled in the accident analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the trip setpoint value at the sensor to the point at which the equipment reaches the required functional state (e.g., control and shutdown rods fully inserted in the reactor core).
3.2 Proposed Changes
3.2.1 Proposed Changes to the TSs
Clintons LCO 3.3.1.1 requires the instrumentation for each Function in TS Table 3.3.1.1-1, Reactor Protection System Instrumentation, to be operable. Associated SR 3.3.1.1.17 requires the licensee to verify that the RPS response time is within limits for the functions specified in the table. Similarly, LCO 3.3.6.1 requires the primary containment and drywell isolation instrumentation for each Function in TS Table 3.3.6.1-1, Primary Containment and Drywell
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Isolation Instrumentation, to be operable. To assure the LCO is met, SR 3.3.6.1.7 requires the licensee to verify that the isolation system response time is within limits for functions specified in the table. LCO 3.5.1, ECCS - Operating, requires, in part, that each ECCS injection/spray subsystem be operable. To assure the LCO is met, SR 3.5.1.8 requires the licensee to verify that the ECCS response time is within limits for each injection/spray subsystem.
TS 1.1, Definitions, contains, in part, the definitions for emergency core cooling system (ECCS) response time, isolation system respons e time, and reactor protection system (RPS) response time. They each describe testing criteria and state acceptable means to measure equipment response time. Those definitions would be revised to state the following (with changes underlined):
Emergency Core Cooling System (ECCS) Response Time
The ECCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.
Isolation System Response Time
The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.
Reactor Protection System (RPS) Response Time
The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.
3.2.2 Proposed Variations
In addition to the changes associated with TSTF-332, the licensee identified the following proposed variations that would move the following notes in individual RTT SRs to the TS bases:
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SR 3.3.1.1.17 Note 2: For Functions 3, 4, and 5 in Table 3.3.1.1-1, the channel sensor s are excluded.
SR 3.3.6.1.7 Note: Channel sensors are exclud ed.
SR 3.5.1.8 Note: ECCS actuation instrumentation is exclud ed.
3.2.3 Proposed Changes to TS Bases
Consistent with 10 CFR section 50.36(a)(1), the licensee submitted corresponding changes to the TS bases of associated SRs that provide the reasons for the proposed TSs changes (for information only). The regulation at 10 CFR 50.36(a)(1) states that a summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TSs. The licensee shall make changes to the Clinton TS Bases in accordance with TS 5.5.11, Technical Specification (TS) Bases Control Program.
3.3 Evaluation
The licensee proposed to modify the definitions of ECCS response time, isolation system response time, and RPS response time per TSTF-332, as described in attachment 1, section 2.3 of its January 13, 2023, letter.
TSTF-332 includes the following justification for changes to the standard technical specifications (STS):
As stated in NEDO-32291-A, analysis has demonstrated that other Technical Specification testing requirements (CHANNEL CALIBRATIONS, CHANNEL CHECKS, CHANNEL FUNCTIONAL TESTS, and LOGIC SYSTEM FUNCTIONAL TESTS) and actions taken in response to NRC Bulletin 90-01 Supplement 1 are sufficient to identify failure modes or degradation in instrument response times and assure operation of the analyzed instrument loops within acceptable limits. This Topical Report also identifies that there are no known channel sensor failure modes identified that can be detected by response time testing that cannot also be detected by other Technical Specification required surveillances. Therefore, certain sensor response times need not be measured, and can be assumed to be the designed response time. By revising the definitions for response time testing and the associated implementing SR Bases, the details of which channel sensors are measured and which are allowed to be assumed can be appropriately delineated.
In its January 13, 2023, letter, the licensee cited license Amendment No. 98, where Clinton was approved to modify RTT-related TS using NE DO-32291. This amendment allowed relaxation of TS requirements by adding Notes to SRs 3.3.1.1.17, 3.3.6.1.7, and 3.5.1.8, to exclude certain instrumentation from RTT. In addition to adopting TSTF-332, the licensee proposed a variation to remove those SR notes that contain exceptions to RTT requirements, as described in attachment 1, section 2.2 of the January 13, 2023, letter.
The NRC staff reviewed the proposed revisions and determined that the addition of the [i]n lieu of measurement, response time may be verified text to the RTT definitions is a global change
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to the identified SRs, and has a similar effect as the individual exclusion notes in the current TS.
The exclusion notes in SRs 3.3.1.1.17, 3.3.6.1.7, and 3.5.1.8, would be duplicative when the RTT definitions are updated as proposed by the license amendment request. Therefore, the staff considers the adoption of TSTF-332 together with moving the information from the SR exclusion notes to the TS bases to be an editorial c hange because the change is to the wording only and does not change the way the plant is operated or kept within its TS. Also, the proposed changes will align the Clinton TS to the standardized language and formatting of the STS. The affected SRs and TS definitions remain consistent with 10 CFR 50.36(c)(3) because the revised SRs, as supported by the revised definitions, continue to use an NRC approved methodology to verify that the affected instrumentation response time is adequate. The NRC staff notes that the basis for the approval of this methodology is discussed in the NRC staffs SE for Amendment No. 98 to the Clinton license. Using the NRC approved methodology ass ures that the necessary quality of the affected systems and components is maintained, that facility operation will be within safety limits, and that the LCO will be met.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Illinois State official was notified of the proposed issuance of the amendment on October 11, 2023. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR, part 20. The NRC staff has determined that the amendment involves no signific ant increase in the amounts, and no significant change in the types, of any effluents that may be releas ed offsite, and that there is no significant increase in individual or cumulative oc cupational radiation ex posure. The Commission has prev iously issued a proposed finding that the amendment involv es no significant hazards consideration, published in th e Federal Register on February 21, 2023 (88 FR 10555), and there has been no public comment on such finding. Ac cordingly, the amendment meets the eligibility criteria for catego rical 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 discu ssed 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) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the is suance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: K. West
Date of Issuance: November 22, 2023
ML23284A251 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/STSB/BC(A) OGC NAME JWiebe SRohrer/(ABaxter) MJardaneh MWoods DATE 10/18/23 10/12/23/(11/20/23) 9/27/2023 11/17/2023 OFFICE NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME JWhited Swall, for JWiebe DATE 11/21/23 11/22/23