ML23338A110
| ML23338A110 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/06/2024 |
| From: | Joel Wiebe Plant Licensing Branch III |
| To: | Rhoades D Constellation Energy Generation |
| Wiebe J | |
| References | |
| EPID L-2023-LLA-0034 | |
| Download: ML23338A110 (1) | |
Text
February 6, 2024
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, UN IT NO. 1 - ISSUANCE OF AMENDMENT NO. 252 RE: REVISION OF TECHNICAL SPECIFICATION 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR" (EPID L-2023-LLA-0034)
Dear Mr. Rhoades:
The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 252 to Facility Operating License No. NPF-62 for the Clinton Power Station, Unit No. 1. The amendment is in response to your application dated March 1, 2023, as supplemented by letter dated October 16, 2023.
The amendment revises diesel generator starting air system requirements in Technical Specification 3.8.3, "Diesel Fuel Oil, Lube Oil, and St arting Air" to allow a starting air system to be considered operable with one of two starting air receivers at or above required pressure.
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. 252 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. 252 License No. NPF-62
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Constellation Energy Generation, LLC (the licensee), dated March 1, 2023, as supplemented by letter dated October 16, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I;
B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;
C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations;
D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and
E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
Enclosure 1
- 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-62 is hereby amended to read as follows:
(2) 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. 252, are hereby incorporated in the license. Constellation Energy Generation, LLC 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: February 6, 2024
ATTACHMENT TO LICENSE AMENDMENT NO. 252
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 3.8-20 3.8-20 3.8-21 3.8-21 3.8-22 3.8-22 3.8-23 3.8-23
(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 nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required;
(5) Constellation Energy Generation, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components;
(6) Constellation Energy Generation, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility. Mechanical disassembly of the GE14i isotope test assemblies containing Cobalt-60 is not considered separation; and
(7) Constellation Energy Generation, pursuant to the Act and 10 CFR Parts 30, to intentionally produce, possess, receive, transfer, and use Cobalt-60.
C. This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1) Maximum Power Level
Constellation Energy Generation is authorized to operate the facility at reactor core power levels not in excess of 3473 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.
(2) Technical Specifications and Environmental Protection Plan
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 252, are hereby incorporated into this license.
Constellation Energy Generation,LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
Amendment No. 252 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3
3.8 ELECTRICAL POWER SYSTEMS
3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air
LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air system shall be within limits for each required diesel generator (DG).
APPLICABILITY: When associated DG is required to be OPERABLE.
ACTIONS
NOTE-------------------------------------
Separate Condition entry is allowed for each DG.
CONDITION REQUIRED ACTION COMPLETION TIME
A. One or more DGs with A.1 Restore fuel oil level 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> fuel oil level less to within limits.
than a 7 day supply and greater than or equal to a 6 day supply.
(continued)
CLINTON 3.8-20 Amendment No. 252 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
B. One or more DGs with B.1 Restore lube oil 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> lube oil inventory less inventory to within than a 7 day supply and limits.
greater than or equal to a 6 day supply.
C. One or more DGs with C.1 Restore fuel oil 7 days stored fuel oil total total particulates to particulates not within limit.
within limit.
D. One or more DGs with D.1 Restore stored fuel 30 days new fuel oil oil properties to properties not within within limits.
limits.
(continued)
CLINTON 3.8-21 Amendment No. 252 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
E. Required Actions and E.1 Declare associated DG Immediately associated Completion inoperable.
Time not met.
One or more DGs with diesel fuel oil, lube oil, or starting air system not within limits for reasons other than Condition A, B, C, or D.
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3.8.3.1 Verify each fuel oil storage tank contains In accordance a 7 day supply of fuel. with the Surveillance Frequency Control Program
SR 3.8.3.2 Verify lube oil inventory is a 7 day In accordance supply for each diesel engine. with the Surveillance Frequency Control Program
(continued)
CLINTON 3.8-22 Amendment No.
Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3
SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY
SR 3.8.3.3 Verify fuel oil properties of new and In accordance stored fuel oil are tested in accordance with the Diesel with, and maintained within the limits of, Fuel Oil the Diesel Fuel Oil Testing Program. Testing Program
SR 3.8.3.4 Verify each air start system pressure is In accordance 200 psig. with the Surveillance Frequency Control Program
SR 3.8.3.5 Check for and remove accumulated water from In accordance each fuel oil storage tank. with the Surveillance Frequency Control Program
CLINTON 3.8-23 Amendment No. 252 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO. 252 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 March 1, 2023 (Agencywide Documents Access and Managem ent System (ADAMS) Accession No. ML23060A258), as supplemented by letter dated October 16, 2023 (ML23289A069),
Constellation Energy Generation, LLC (the licensee) submitted a license amendment request (LAR) for Clinton Power Station (Clinton), Unit No. 1, to modify starting air system requirements in Technical Specification (TS) 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air." The proposed changes would allow a starting air system to be considered operable with one of two starting air receivers at or above required pressure.
2.0 REGULATORY EVALUATION
2.1. System Description
The onsite standby power source consists of three diesel generators (DGs) (Divisions I, II, and III). Each DG has an air start system with enough capacity for five successive start attempts without recharging the air start receiver when the receiver pressure is greater than or equal to 200 pounds per square inch gauge (psig). The air starting systems for Divisions I, II, and III, are independent and redundant.
Division I and II DGs are tandem-mounted 12-and 16-cylinder engines with a center-mounted generator. They have independent starting air systems with each system containing two 100 percent capacity alternating current (AC) motor-driven air compressors, one starting air dryer, two air receiver tanks, six air motors, and associated piping, valves, and controls.
The Division III DG has a single 16-cylinder engine with an air system containing two 100 percent capacity AC motor-driven air compressors, one starting air dryer, two air receiver tanks, four air motors, and associated piping, valves, and controls.
Enclosure 2
2.2 Description of the Proposed Changes
The licensee proposes to change TS 3.8.3 by deleting Condition E (air receiver pressure below requirement) that allows a required DG to be considered operable with reduced starting air capability, and by clarifying that adequate pressure is required for the associated starting air system to be considered operable within Surveillance Requirement (SR) 3.8.3.4.
Current TS 3.8.3 starting air system requirements:
LCO [limiting condition for operation] 3.8.3: The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).
CONDITION REQUIRED ACTION COMPLETION TIME E. One or more DGs with E.1 Restore starting air 48 Hours required starting air receiver pressure to receiver pressure 200 psig.
< 200 psig and 140 psig.
F. Required Actions and F.1 Declare associated Immediately associated Completion DG inoperable.
Time not met.
One or more DGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, D, or E.
SR 3.8.3.4: Verify each required DG air start receiver pressure is 200 psig.
Frequency: In accordance with the Surveillance Frequency Control Program.
The licensee proposed to delete condition 3.8.3.E in its entirety, renumber Condition F to Condition E (with associated starting air system changes), and to modify LCO 3.8.3 and SR 3.8.3.4 to read as follows:
LCO 3.8.3: The stored diesel fuel oil, lube oil, and starting air system shall be within limits for each required diesel generator (DG).
CONDITION REQUIRED ACTION COMPLETION TIME E. Required Actions and E.1 Declare associated Immediately associated Completion DG inoperable.
Time not met.
One or more DGs with diesel fuel oil, lube oil, or starting air system not within limits for reasons other than Condition A, B, C, or D.
SR 3.8.3.4: Verify each air start system pressure is 200 psig.
Frequency: In accordance with the Surveillance Frequency Control Program.
2.3 Proposed Changes to TS Bases
Consistent with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36(a)(1), the licensee submitted corresponding changes to the TS bases that provide the reasons for the proposed TS changes. 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 TS. With this LAR, the licensee submitted changes to the Clinton TS bases associated with the proposed TS changes. TS bases changes will be made consistent with TS 5.5.11, TS Bases Control Program.
2.4 Regulatory Discussion
Regulation 10 CFR, Part 50, Domestic Licensing of Production and Utilization Facilities, Appendix A, General Design Criteria [GDC] for Nuclear Power Plants, Criterion 17, "Electric Power Systems" requires an onsite electric power system for the functioning of structures, systems, and components important to safety. GDC 17 requires the onsite electric power system to have sufficient independence and redundancy to perform their safety functions, assuming a single failure. GDC 17 requirements provide assurance that electric power will be available for systems necessary (i) to prevent fuel damage in anticipated operational occurrences and (ii) to maintain core cooling and containment integrity in postulated accidents.
Regulation 10 CFR 50.36, Technical specifications, provides the regulatory requirements for the content of the TS. It 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, 10 CFR 50.36(c) requires that TS include items in five specific categories related to station operation. These categories are (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls.
Regulation 10 CFR 50.36(c)(2)(i), Limiting conditions for operation, states, in part, that TSs will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Section 50.36(c)(2)(i) further states that [w]hen a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.
Regulation 10 CFR 50.36(c)(3), Surveillance requirements, states that [s]urveillance requirements are requirements related to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
NUREG-0800, Revision 3, Standard Review Plan (SRP) for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [light-water reactor] Edition, Section 9.5.6, Emergency Diesel Engine Starting System, (ML070550034) cont ains air start system criteria and guidance necessary to meet GDC 17 requirements including that each diesel engine should have a dedicated air starting system consisting of an air compressor, an air dryer, one or more air receiver(s), piping, injection lines and valves, and devices to crank the engine as recommended by the engine manufacturer.
NUREG-1434, Revision 5, Standard Technical Spec ifications for General Electric Plants, Boiling Water Reactor-6 (ML21271A582), provides ex ample TS LCOs and acceptable remedial actions that meet the requirements in 10 CFR 50.36(c)(2)(i) for a standard plant design.
3.0 TECHNICAL EVALUATION
3.1 NRC Staff Evaluation
The licensee proposed to change the Clinton TS by applying the operability criteria to the DG air start system at the system level (i.e., minimum one of two air receivers operable), instead of at the subsystem level, which is two air start receiver subsystems operable within the DG air start systems. The LAR requests modification of LCO 3.8.3, deletion of TS 3.8.3 Condition E, and modification of SR 3.8.3.4 requiring each air start system pressure remain greater than or equal to 200 psig for operability. Currently, LCO 3.8.3 requires each air start subsystem to be within limits; and TS 3.8.3 Condition E (with one or more DGs with starting air receiver pressure less than 200 psig and greater than or equal to 140 psig) allows up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to repressurize the inoperable air receiver(s) to greater than or equal to 200 psig. When Condition E is not met, Condition F requires the licensee to immediately declare the DG inoperable. SR 3.8.3.4 currently requires a pressure of greater than or equal to 200 psig for each of two air receivers in a DGs air start system.
The proposed changes would modify the starting air requirements in TS 3.8.3 such that the LCO would require the system level starting air to be within limits. The proposed change also would modify the limit specified in SR 3.8.3.4 where each air start system (i.e., one or both air receivers) would be required to demonstrate that it maintains pressure greater than or equal to 200 psig without aid of its refill compressor. When the pressure in a DGs air start system (i.e.,
both air receivers) is less than 200 psig, the licensee would directly enter new Condition E (current Condition F) and declare the DG inoperable immediately.
Section 9.5.6 of the SRP contains specific criteria and guidance for compliance with GDC 17 indicating each diesel engine should have a dedicated air starting system consisting of an air compressor, an air dryer, one or more air receiver(s), piping, injection lines and valves, and devices to crank the engine as recommended by the engine manufacturer. This SRP 9.5.6 further specifies that a single failure in any one of the systems will affect only its own DG and each of the starting systems can crank a cold diesel engine five times without air receiver recharging and that alarms should alert operating personnel if the air receiver pressure falls below the minimum allowable value.
The licensee defines the design-basis for the DG air start system in Section 9.5.6.1.1 of the Clinton Updated Safety Analysis Report (USAR) (M L22111A207) as related to its respective DG (Division I, II, or III). Each DG air start system contains redundant air receivers with rated capacity to start its supported DG five times without recharging the associated air receiver. The USAR describes the safety design-basis of the air start system as follows:
- a. The diesel-generator starting systems for the Divisions I, II, and III diesel engines are independent and redundant for each division. Each diesel generator starting system consists of two full capacity air starting subsystems. Each subsystem has a rated capacity capable of starting its respective engine set five times without recharging the associated air receiver. The rated air capacity of each subsystem is 93 ft.3 at 250 psig for the Division I and II DGs and 64 ft. 3 at 240 psig for the Division III DG. All three DGs are capable of multiple successive starts without recharging the air receiver tank when the air receiver pressure is below the rated air pressure but at least 200 psig.
- b. The starting system initiates an engine start so that within 12 seconds after receipt of the start signal the diesel-generator is operating at rated speed, voltage, and frequency.
- c. A failure of a single active or passive component for one division will not prevent another division from performing its intended function.
- d. The portions of the starting system essential to the starting of a diesel engine are of Seismic Category I design. The entire diesel-generator starting system is housed in a Seismic Category I structure capable of protecting it from extreme natural phenomena, missiles, and the effects of pipe whip, jet impingement and water spray from high-and moderate-energy pipe breaks.
The licensee does not propose any physical modifications or configuration change to the DG air start system and remains compliant with the current design-basis as defined in the USAR, Section 9.5.6. The licensee does not request any change to the USAR, and each DG air start system contains two air starting subsystems containing an air start receiver. Failure of one DG air start subsystem will not prevent the other subsystem from starting the respective DG. In its supplemental letter dated October 16, 2023, the licensee clarified that a failure of a single receiver alone will not result in the associated DG being inoperable because each DG starting air system consists of two full capacity air starting subsystems and each subsystem includes an air receiver. Therefore, redundancy is included in the DG air start system.
The licensee requests applying operability criteria to each DGs air start system rather than the current TS requirement for two air start receivers, which is consistent with the standard TS requirements in NUREG-1434. System operability will be defined by each DG air start system meeting the SR 3.8.3.4 pressure requirement. The proposed changes to revise LCO 3.8.3 and SR 3.8.3.4 would allow, at minimum, the use of a single air start receiver charged to greater than or equal to 200 psig to perform the DG starting function. The licensee provided the proposed TS bases change for this SR stating, The surveillance is met when the pressure in at least one of the two air start receivers for an associated DG is greater than or equal to 200 psig.
This is acceptable because each DG starting system consists of two full capacity air starting subsystems that include an air compressor and air receiver tank, and either subsystem is capable of starting the DG. Section 9.5.6.2 of the USAR defines the capability of a single air receiver providing sufficient pressure to support air start system stating, Only two of the four air start motors need to be engaged to the flywheel ring gear of the high-pressure core spray (HPCS) diesel engine to start the engine. Only three of the six Division 1 and 2 air start motors need to be engaged to start both engines on a skid. Therefore, the use of a single air receiver is sufficient to support the required function for its DG air start system and SR 3.8.3.4 requires verification that each air start system pressure is greater than or equal to 200 psig.
In accordance with the Clinton USAR, either of the two air starting subsystems can start their respective engine set five times without recharging the associated air receiver. In its request for additional information (RAI) dated August 18, 2023 (ML23230B168), the NRC staff asked the licensee to confirm that the system meets the five start criteria (12 seconds) with an air receiver at the proposed SR pressure of 200 psig and how the pressure is defined, calculated, tested, and monitored. In its letter dated October 16, 2023, the licensee stated that the ability to start the engine set five times without recharging the associated air receivers was demonstrated for Division I DG as part of initial plant startup testing and subsequently as part of post-modification testing following implementation of a design change. The licensee further indicated the requirement to start the DG and reach rated speed, voltage, and frequency within 12 seconds after receipt of the start signal was confirmed in accordance with the USAR, Section 9.5.6.1.1, and that Division I DG test results bound the other DGs due to the physical differences between the three DGs. The license clarified that periodi c surveillance testing is performed with one of the two air receivers isolated to confirm the ability of each subsystem to start its DG. Therefore, SR 3.8.3.4 continues to require the 200-psig pressure to meet the five start capability for its respective DG within the specified start time.
In its RAI dated August 18, 2023, the NRC staff a sked the licensee to provide descriptions of components and operability of the air start system. In its letter dated October 16, 2023, the licensee provided a detailed description of the ai r start system components and function for all three DGs.
The Division I and II DGs are tandem-mounted 12-and 16-cylinder engines with a center-mounted generator. The Division I and II DGs have independent starting air systems with each system containing two 100 percent capacity AC motor-driven air compressors, one starting air dryer, two air receiver tanks, six air motors, and associated piping, valves, and controls. The licensee further defines each air start system for the Division I and II DGs, consisting of two full capacity subsystems that contain one air receiver, two divisional air start solenoids, three air motors, and associated piping, valves, and controls. When the DG starting logic is actuated, four air start solenoids open the pilot valves allowing air from the starting air header to actuate and open the main air start valves. This provides a flowpath for air from the starting air receivers to the three air start motors on each tandem engine. The licensee indicated two air start motors on one engine and a single motor on the other engine are required to engage to start the engines.
The Division III DG has a single 16-cylinder engine. The Division III air start system consists of two full capacity subsystems that contain one air receiver, one air start solenoid, two air motors, and associated piping, valves, and controls. When a start signal is received, the air start solenoids on both trains energize and cause the associated valves to open. Only one pair of air start motors is required to start the Division III DG.
In accordance with SRP 9.5.6, alarms should alert operating personnel if the air receiver pressure falls below the minimum allowable value. The licensee indicates that monitoring of receiver pressure is performed locally with an alarm in the main control room. In addition, Section 9.5.6.5 of the USAR contains a description of the instrumentation for each DG starting system consisting of two locally mounted pressure switches which monitor the air pressure in the air receivers. These switches start the air compressor, provide a low-pressure alarm on the local control panel, and input to the annunciators in the main control room. Therefore, the design ensures the air start pressure is monitored to the SR 3.8.3.4 pressure requirement (greater than or equal to 200 psig).
With the proposed TS changes, each DG air start system functional performance remains unchanged based on the minimum 200 psig system pressure requirement and five start attempt capability. The licensee indicated a single air receiver can perform the air start system requirement. System redundancy is maintained thr ough the multiple DG subsystems (Divisions I, II, and III) and the DG operability requirements within TS 3.8.1, AC Sources - Operating. In the event an air start system pressure decreases below required SR 3.8.3.4 pressure, then the impacted DG will be declared inoperable immediately and the appropriate TS 3.8.1 Condition will be entered.
3.2 NRC Staff Conclusion
The NRC staff finds that the proposed changes meet the guidance in NUREG 0800, Section 9.5.6, because each DG has a dedicated air starting system consisting of an air compressor, an air dryer, an air receiver, piping, injection lines and valves, and air motors to crank the engine.
Based on above, the licensee continues to meet the requirements of GDC 17, which requires the onsite electric power system to have sufficient independence and redundancy to perform its safety function, assuming a single failure. Each DG contains a dedicated air starting system consisting of an air compressor, an air dryer, one or more air receiver(s), piping, injection lines and valves. Each air start system is independent and physically separated from the other systems and only serve one redundant DG. A single failure in any one of the air start systems will affect only its own DG. Each of the air st arting systems continue to meet the five start attempts requirement without air receiver recharging to perform its safety function.
In conclusion, the existing plant design contains redundant air starting subsystems within each DG air start system to support DG system operabilit y. As discussed above, the air start system provides adequate system pressure to perform the safety function for its respective DG. With the proposed TS change, the DG air start system would be verified within its pressure limits as required by SR 3.8.3.4. The proposed TS 3.8.3 condition changes would direct the licensee to immediately declare the associated DG inoperable when the air start system pressure is below 200 psig. Based on the above, the NRC staff finds the proposed changes to TS 3.8.3 in the LCO, SR 3.8.3.4, and deletion of Condition E (with associated changes to existing Condition F),
meet the LCO and SR requirements described in 10 CFR 50.36, paragraphs (c)(2)(i) and (c)(3),
respectively, to ensure the lowest functional capability of the air start system is maintained.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Illinois State official was notified of the proposed issuance of the amendment on December 4, 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, and changes SRs.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in i ndividual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, published in the Federal Register on July 11,
2023 (88 FR 44164), and there has been no public comment on such finding. Accordingly, 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 discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: G. Curran D. Nold K.West
Date of Issuance: February 6, 2024
ML23338A110 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/STSB/BC(A) NRR/DSS/SCPB/BC NAME JWiebe SRohrer CAshley BWittick DATE 12/6/2023 12/5/2023 12/11/2023 12/1/2023 OFFICE NRR/DEX/EEEB/BC OGC NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME WMorton RSiegman JWhited JWiebe DATE 12/8/2023 1/5/2024 2/6/2024 2/6/2024