ML24092A345
| ML24092A345 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/01/2024 |
| From: | Lueshen K Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML24092A344 | List: |
| References | |
| RS-24-031 | |
| Download: ML24092A345 (1) | |
Text
Constellation~
RS-24-031 April 1, 2024 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 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 23 In accordance with the requirements of 10 CFR 50.71, "Maintenance of records, making of reports," paragraph (e)(4), Constellation Energy Generation, LLC (CEG) submits Revision 23 to the Updated Safety Analysis Report (USAR) for Clinton Power Station (CPS).
The enclosed USAR Revision 23 is being provided to the NRC in electronic format on EIE and is being submitted in its entirety, constituting total replacement copies. Also enclosed in electronic format on EIE, is the Clinton Operational Requirements Manual (ORM) updated through Revision 94 and Clinton Technical Specifications Bases (TSB) updated through Revision 22-09. USAR pages changed as a result of this update are delineated with "Rev. 23, March 2024" in the 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 10 CFR 50.59 and concluded that the changes do not require prior NRC approval.
Attachment A provides a brief summary of the changes incorporated into USAR Revision 23.
Attachment B provides the required summary report pursuant to 10 CFR 50.59(d)(2).
Attachment C contains a summary of regulatory commitment changes.
Attachment D summarizes the changes to the ORM.
Attachment E provides a required summary report pursuant to 10 CFR 72.48.
Attachment F contains the directory path, filename, and size of each individual file.
April 1, 2024 U. S. Nuclear Regulatory Commission Page 2 of 2 As required by 10 CFR 50.71(e)(2)(i), I, Director - Licensing, 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 at 779-231-6058.
Respectfully, Kevin Lueshen Director - Licensing Constellation Energy Generation, LLC Attachments: A - CPS USAR Revision 23 Change Summary Report B - CPS 10 CFR 50.59 Summary Report C - CPS Summary of Regulatory Commitment Changes D - CPS Summary of Operational Requirements Manual Changes E - CPS 10 CFR 72.48 Summary Report F - CPS Electronic File Directory Structure
Enclosures:
001 - EIE, Clinton USAR, Revision 23 002 - EIE, Clinton ORM, Revision 94 003 - EIE, Clinton TSB, Revision 22-09 cc:
NRC Regional Administrator, Region III NRC Senior Resident Inspector - Clinton Power Station NRC Project Manager, NRR NRC Region III - Library
- Lueshen, Kevin Digitally signed by Lueshen, Kevin Date: 2024.04.01 12:40:46
-05'00'
Attachment A CPS USAR Revision 23 Change Summary Report Page 1 of 4 USAR 2021-001 Update UFSAR Appendix E Cable Tray Drawings Rework Appendix E cable tray drawings with editorial changes to correct divisional color code for the cable trays. Attachment 1a has compete summary of changes and attachment 1b for Appendix E figure markups. UFSAR Appendix E Figures 2, 3, 4, 5, 9, 10, 11, 18.
USAR 2022-001 Revise Numbers to Reflect GNF3 EC 630772 Change makes minor changes to postulated peak suppression pool temperatures reflecting GNF3 fuel load. This change affected Section 15.9.
USAR 2022-003 Revise UFSAR to describe the RAT B is connected to an SVC while ERAT is connected to MSCs UFSAR Change 2020-021 associated with EC 628200 revised the UFSAR to state both RAT B and the ERAT transformers would be connected to Mechanically Switched capacitor Banks (MSCs). EC 628200 only connected the ERAT to MSCs while RAT B is still connected to an SVC. This change revises the UFSAR to correct this information. This change affects Sections 8.2.2.1, 8.3.1.1.1, 8.3.1.1.2.
USAR 2022-006 Update Appendix F Table 1.8-2 to include 1FW016 and 1FW021 Change adds flushing line inboard and outboard isolation valves 1FW016 and 1FW021 to Appendix F Table 1.8-2 Safe Shutdown Equipment List by Fire Zone. Add 1FW016 and 1FW021 and associated table field data by inserting in the respective alphabetical sequence by fire zone (page F1.1-34). Add reference Note 15: To prevent spurious operation as a result of induced fault, 1FW016 and 1FW021 are administratively maintained closed with supply breakers open (page F1.1-34A). This change affected Appendix F, Table 1.8-2, Pages F1.1-34, 34A.
USAR 2022-011 Update CPS/USAR Table 5.4-2 System Flow Rate Change updates the RWCU max system flow rate by 17.7% as per SIA evaluation. This change supports EC 637239. This change affected CPS/USAR Table 5.4-2.
USAR 2022-012 Site Acreage Correction Change corrects discrepancies identified in site acreage values. Change affects USAR Section 1.2.2.1.1, Location, USAR Section 2.1.1.2, "Site Area Map," and USAR Table 2.1-1, Acreage of Clinton Power Station. (Pages 1.2-8, 2.1-2, 2.1-9), USAR Figure 2.1-8.
Attachment A CPS USAR Revision 23 Change Summary Report Page 2 of 4
USAR 2022-013 Add RR Bay to Secondary Containment (License Amendment 246)
Change adds RR Bay to Secondary Containment (License Amendment 246). Change affected Section 3.2, Pages 3.2-25, 3.2-32; Section 3.5, Pages 3.5-11, 3.5-25; Section 3.8, Pages 3.8-31, 3.8-32, 3.8-34; Section 6.2, Pages 6.2-51, 6.2-52, 6.2-53, 6.2-57, Fig 6.2-132; Section 6.4 Fig 6.4-3; Section 6.5, Pages 6.5-1, 6.5-2, 6.5-7.
USAR 2022-015 Implement Fire Hose Removal Strategy per Recommendations of EC626822 Changed USAR to remove discussion specific to fire hose. Discussions of fire hose stations will not be removed. This change affected Sections 9.5.2.2.4, Water sprinkler and hose standpipe systems, pages 9.5-11a; Appendix E, Section 4.0 E.3.d Water sprinkler and hose standpipe system, page E4.1-37; and Appendix F, Table 4.2.2.6-2, page F4.2-50.
USAR 2023-001 Change to ANSI references and exemptions in USAR Sections 1.8, 2.3.3, and 2.3.7 as identified by IR 4539953 Change removes proposed from section heading, reference to ANS 2.5-1984 proposed, and exceptions 1 and 3 on USAR section 1.8, page 1.8-17. Removed reference to ANSI/ANS 2.5 (1984) on USAR Section 2.3.3, page 2.3-17. Lastly, changes indicated by IR 4539953 as part of the relicensing process and to remove redundant/dispositioned references. This change affected USAR Section 1.8 - Regulatory Guide 1.23, Rev 1 (proposed), page 1.8-17; USAR Section 2.3.3 - Onsite Meteorological Measurements Program, Pages 2.3-17.
USAR 2023-002 Section 9.5 Fire Pump NFPA Code Update Change updates to the NFPA code year of the installed FP A pump as supplied by the vendor.
The FP A Pump 0FP01PA was purchased to the 2019 NFPA 20 code but will be committed to and inspected to the original 1976 and 1983 versions of the code respectively. This change affected Section 9.5.1.1, NFPA Codes Table (page 9.5-5) and Section 9.5.1.2.2.3 (page 9.5-11).
USAR 2023-003 UFSAR References Incorrect NFPA Code Version Change corrects newly added table that is inappropriately named "NFPA Code Commitments" and the word "commitment" is used in two column names in the table when it should not be.
This change affected Section 9.5.1.2.2.5, Halon Suppression Systems.
Attachment A CPS USAR Revision 23 Change Summary Report Page 3 of 4
USAR 2023-006 Deviation from NFPA 51B-1976 Change revised the following:
Inserted asterisk
- next to NFPA 51B-1976 under section 2.2.5 - Applicable NFPA Codes, page 2-11, with a reference to See NFPA Standard No. 51B under Checklists section of this report for description.
Updated NFPA Code Conformance Report to remove reference to NFPA 51B, Cutting and Welding Processes from Section 4.3.16 Additional Codes Reviewed for Compliance.
NFPA Standard No. 51B Fire Prevention in Use of Cutting and Welding Processes, 1976, Checklists section of the NFPA Code Conformance Report, pages 1-5 to be updated to remove and replace with statement: NFPA 51B is not a code of record. All hot work activities are covered under procedure OP-AA-201-004. For prior requirements and recommendations, see historical record of this report.
Revised the UFSAR BTP comparison items to remove NFPA 51B from the Table on Page 9.5-6, Revised Clintons position under section B.3.a of Compliance with BTP APCSB 9.5-1, Appendix A, Plants Under Construction and Operating Plants, to include A trained fire watch will be established when required per OP-AA-201-004.
Revised Clintons position under section G.1 of Compliance with BTP APCSB 9.5-1, Appendix A, Plants Under Construction and Operating Plants, to include NFPA 51 provides guidance for Oxygen-Fuel Gas Systems for Welding and Cutting.
These changes affected NFPA Code Conformance Report, Section 2.2.5, page 2-11; NFPA Code Conformance Report, "Checklists" Section, NFPA 51B, pages 1-5; NFPA Code Conformance Report, Section 4.3.16 USAR, Section 9.5.1.1, page 9.5-6; USAR, Appendix E, Section B.3.a, page E4.1-6 USAR, Appendix E, Section G.1, page E4.1-53.
USAR 2023-008 Abandonment of Hose Houses #5, 8, and 10, and Associated Fire Hydrants Changes Hose houses #5, 8, and 10, as well as the associated fire hydrants along the east boundary of the unit 2 excavation pit are being abandoned. The USAR currently includes a description of the distances between all of the fire hydrants, which needs to be updated to reflect the new distances between active hydrants following abandonment. This change affects UFSAR Section 9.5.1.2.2.3, "Fire Protection Water Supply System" (page 9.5-11) and UFSAR Appendix E Section 4.E.2, "Fire Protection Water Supply Systems," part g (pages E4.1-34, E4.1-35).
USAR 2023-009 Update USAR with Correct Design Inputs for RR Pump Design Evaluation This change associated with EC 639209 revised the USAR to state that the number of startups and shutdowns considered in the recirculation pump design evaluation were 120 and 111 respectively. This is consistent with procurement specification 21A9450, which contains the correct inputs specified by GE. This change affected Section 3.9.1.1.11.
Attachment A CPS USAR Revision 23 Change Summary Report Page 4 of 4
USAR 2023-010 UFSAR Updates for Clinton Unit 1 Cycle 22 Reload Evaluation Change reflects edits necessary for the upcoming C1C22 reload for Clinton Unit 1. The changes include several reference updates and editorial changes. There was also an update to a reference issued by GNF, which has been incorporated via reference in Section 6.3, which has been requested per ACIT 04489407-06. This change affected UFSAR Section 4.2 Page 10, Section 5.2 Pages 6, Section 6.3 Pages 26, 31, 42, and 53, Section 15.0 Page 10, Section 15.1 Pages 13 and 13a, Section 15.6 Page 18, Section 15D Pages 6, 11, and 45.
USAR 2023-011 RAT B Static Var Compensator (SVC) Long Term Abandonment This Engineering Change (EC) 627131 is abandoning the Static Var Compensator (SVC) on Reserve Auxiliary Transformer (RAT) B. Additionally, EC 627131 installs Mechanically Switched Capacitor (MSC) banks and Mechanically Switched Capacitor Control (MSCC) system along with placing ON-LOAD Tap Changer (OLTC) on RAT B in "AUTO." This change affects Sections 8.2.2.1, 8.3.1.1.1, 8.3.1.1.2.
USAR 2023-012 Partial Installation of MSIV Leakage Control System Abandonment Change updates discussion of installation of the blind coupling on line 1IS01AC part of the MSIV Leakage Control System Abandonment Markup. This change affected Table 3.6-2 on page 3.6-41, D3.6.2.3 on page D3.6-6; D3.6.2.3.1 on page D3.6-7; Figure 3.6-1 on Sheet 54.
Attachment B CPS 10 CFR 50.59 Summary Report Page 1 of 3 This attachment contains 50.59 evaluation summaries performed for Clinton Power Station (CPS) during this reporting period.
Activity Number /Title CL-2019-E-031 REVISE SECONDARY CONTAINMENT DESIGN BASIS TO CREDIT FUEL BUILDING RAILROAD AIRLOCK Description of Activity The proposed activity revises the definition for the secondary containment boundary at the Fuel Building Railroad Airlock (FBRA) to ensure that both secondary containment capability and tornado protection are maintained when required. Specifically, this involves utilizing the FBRA and outer door as the secondary containment boundary when the inner door is open and no adverse weather conditions exist. In addition, specific, situational control of the inner door is included as part of this effort.
Reason for Activity The FBRA inner door, Equipment ID Number (EIN) 1HC72G/1SD1-30 currently forms part of the secondary containment boundary. Each time this door is opened to move equipment in and out of the Fuel Building, the secondary containment is declared inoperable, and Technical Specification Action Statement 3.6.4.1.A is entered. This Action Statement requires the secondary containment to be restored within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, which imposes a burden on plant operations, especially during ISFSI campaigns where the large dry casks are moved into and out of the Fuel Building. Therefore, it is desired to revise the definition of the secondary containment boundary at the FBRA to ensure that both secondary containment capability and tornado protection are maintained when required. Specifically, this involves utilizing the FBRA and outer door as the secondary containment boundary when the inner door is open and no adverse weather conditions exist. In addition, specific, situational control of the inner door is included as part of this effort.
The FBRA is a limited leakage structure constructed of structural steel and steel siding that includes the inner door 1HC72G/1SD1-30 and outer door 1HC70G/1SD1-31. The FBRA and outer door are capable of maintaining -0.25 inches water column pressure in the secondary containment.
The NRC challenges identified in NRC Integrated Inspection Report 05000461/2015003 related to loss of tornado wind and missile protection for the FBRA have been addressed. This 50.59 Evaluation CL-2019-E-031 and EC 628233 includes specific, situational control of the FBRA inner door to ensure tornado protection when required. This 50.59 Evaluation CL-2019-E-031 and EC 628233 revises the definition of the secondary containment boundary at the FBRA to ensure that both secondary containment capability and tornado protection are maintained when required. Specifically, this involves utilizing the FBRA and outer door as the secondary containment boundary when the inner door is open and no adverse weather conditions exist. In addition, specific, situational control of the inner door in included as part of this effort. This
Attachment B CPS 10 CFR 50.59 Summary Report Page 2 of 3 demonstrates secondary containment integrity under the post-LOCA conditions required to perform its design functions. Since EC 395976 performed the modifications, evaluations, and analyses required to ensure the FBRA meets the design and licensing criteria for the secondary containment (except for tornado wind and missile protection), no additional modifications are performed in EC 628233.
Control of the inner door includes verifying there is no severe weather in the area for which the FBRA inner door will be open and having dedicated personnel to close the FBRA inner door should severe weather or a radioactive release occur. Tornado protection is therefore ensured for the secondary containment and other SSCs that require it.
Bases for Not Requiring Prior NRC Approval The proposed activity revises the definition of the secondary containment boundary at the FBRA to ensure that both secondary containment capability and tornado protection are maintained when required. Specifically, this involves utilizing the FBRA and outer door as the secondary containment boundary when the inner door is open and no adverse weather conditions exist. In addition, specific, situational control of the inner door in included as part of this effort. EC 395976 and 50.59 Review CL-2014-E-033 evaluated the FBRA to meet the design and functional requirements of Seismic Category I structures and the secondary containment, including impacts to the SGTS, except for protection from tornado winds and missiles. Per Regulatory Guide 1.117, it is not necessary to postulate a tornado concurrent with a LOCA, but a tornado should be postulated in the post-LCOA long term cooling phase. The secondary containment integrity is ensured in the post-LOCA cooling phase by manual actions to close the FBRA inner door, which also acts as a tornado barrier. These actions include verifying there is no severe weather in the area for the period for which the FBRA inner door will be open and having dedicated personnel to close the FBRA inner door should severe weather or a radioactive release occur. Tornado protection is therefore ensured for the secondary containment and other SSCs that require it.
The proposed activity does not initiate any accidents and does not introduce new failure modes.
There is no possibility for an accident of a different type or a malfunction of an SSC with a different result. DBLFPBs are not exceeded or altered. There is no departure from a method of evaluation described in the USAR.
The proposed activity may be implemented per plant procedures without obtaining a License Amendment.
Attachment B CPS 10 CFR 50.59 Summary Report Page 3 of 3 Activity Number /Title CL-2023-E-048 Disable MSR 1A DRN Line High Level Switch 1LSHD001A Description of Activity The evaluated activity converted the Moisture Separator Reheater IA High-Level trip circuit from its present 2-out-of-3 logic to a 2-out-of-2 logic arrangement. These level switches monitor level between the MSR and the reheater drain tank on a header mounted slightly below the MSR which - initiate a turbine trip due to turbine water induction concerns. This temporary modification will lift leads to disable one level switch (1LSHD001A) from the Turbine EHC Turbine Trip and Monitoring circuit.
Reason for Activity The moisture separator IA drain line level switch ILSHD00IA was proven to be nonfunctional due to stuck contacts. Station leadership was concerned about the half trip condition and potential risk of tripping the turbine while coming up in power from C1R21. Disabling this level switch eliminated the half trip and converted the trip circuit from a 2 out of 3 which is fault tolerant preventing spurious actuation while providing the protective feature to a 2-out-of-2 logic which prevent spurious actuation but may not provide the protective feature if one of the two switches should fail to function. Level switches 1LSHD001B/C will continue to provide level indication and trip the turbine to prevent water induction into the turbine assuming the two switches remain functional.
Bases for Not Requiring Prior NRC Approval The Screening determined the proposed activity involves a change to an SSC that adversely reduces the reliability of the existing SSC design function. Disabling one of the three level switches would eliminate the 2 out of 3 trip logic arrangement which is fault tolerant preventing spurious actuation of the existing tripping scheme for the MSR 1A drain line high water level trip to a 2-out-of-2 logic arrangements which prevents spurious actuation but may not provide the protective feature if one of the two switches should fail to function. Given the extensive history of corrosion these Magnetrol level switches experience each cycle and the deferred maintenance in C1R21, there is increased risk that loss of function (i.e. contacts stuck in the open position) of one of the remaining two level switches may not successfully complete the trip logic to trip the turbine on high water level. Defeating a safety device which could lead to main turbine water induction is a NEIL reportable event per LS-AA-1110, SAF 1.23 (Safety).
The 50.59 evaluation determined that prior NRC approval would not be required for changing the logic from two out of three to a two out of two logic arrangement as it did not present any condition not previously analyzed in the UFSAR.
Attachment C CPS Summary of Regulatory Commitment Changes Page 1 of 1
Subject Inspect or test SX heat exchangers22-002 Existing Commitment Description Periodic inspection will be performed in lieu of testing for GL 89-13 safety related heat exchangers, which are cooled by the Shutdown Service Water system and needed to perform a safety-related function. Inspections will be conducted on a frequency not to exceed once every 5 years (25% grace applies) to verify the heat exchanger is being maintained in a condition capable of performing its heat transfer function."
Revised Commitment Description One time frequency change from every 5 years (25% grace applies) to 6 years (25% grace applies). This will apply to the following PMs, 157769-01, 157769-02, 157771-01, 157771-02, and 157772-02. A history review in passport shows all PMs were completed successfully.
Justification One time frequency extension of PMRQs 157769-01, 157769-02, 157771-01, 157771-02, and 157772-02 are supported by good performance histories of these PMs. Additional time is needed to allow for scheduling in the proper work week per the new cycle plan which is bounded by WC-AA-107 Seasonal Readiness. The shift in Seasonal Readiness requirements will cause these PMs to exceed their late dates prior to execution. Based on the previous results there is a reasonable assurance of no adverse impact of the Heat exchanges to perform their function.
Subject 90 days to perform intake structure inspection 23-001 Existing Commitment Description ATI 401276-01 GL 89-13 commitment is that the intake structure will be inspected on frequency not to exceed once every 5 years (25% grace applies)
Revised Commitment Description One time commitment change 90 days to perform inspection during C1R21 Refueling outage Justification Due to plant conditions, the inspection would not yield adequate results due to pumps in the intake structure operational. This would cause turbulent waters resulting in not allowing the submersible ROV to maintain a steady visual of structure integrity and silt buildup measurements.
Attachment D CPS Summary of Operational Requirements Manual Changes Page 1 of 1
There was one revision to the Clinton Power Station (CPS) Operational Requirements Manual (ORM) that have been made during this reporting period.
The current revision of the CPS ORM is Revision 94.
Revision Number Scope of Revision 94 Revised Sections 2.2 (4.2.12.4 and 5.2.12) testing requirements change to test intervals for logic system functional test from 48 months to 96 months for the Feedwater/Main Turbine Trip. Also, added statement to 5.2.12 siting EC 635782 for basis of 96 month interval for LSFT.
Removed phrase, (Equipment Corrective Action Program Evaluation (CAPE) recommended), from Sections 2.2 and 2.4.
Changed the values for the Loss of Power instrumentation degraded voltage relay voltage setpoints and allowable values to match the new values determined in IP-E-0032 Rev. 3 and 19-AN-19 Rev 5 in attachment 2 Table 11.
Attachment E CPS 10 CFR 72.48 Summary Report Page 1 of 2 There was one 72.48 evaluation performed for Clinton Power Station (CPS) during this reporting period.
Activity Number /Title 72.48-CL-2018-E-022 - HPP-2226-300 Description of Activity The proposed activity incorporates administrative heat load and time limits in HPP-2226-300, MPC-89 Sealing, Drying, Backfilling at Clinton. The limits were incorporated to ensure no component temperatures exceed the CoC limits when using site-specific Auxiliary/Temporary Shielding (Top Hat) at Clinton Power Station (CPS). RRTI-2858-004R0 (RRTI) provides technical justification for the administrative limits in relation to the CPS Top Hat use during short-term operations.
The applicable RRTI short-term configuration at CPS is the loaded, dried, and backfilled MPC in the HI-TRAC, located in the CPS Cask Washdown pit. This configuration is evaluated in CPS Thermal Evaluation, HI-2135813, using the FLUENT Computational Fluid Dynamic (CFD) model. HI-2135813 does not include the top hat in the thermal analysis, thus necessitating the RRTI and administrative limits to ensure no CoC component temperature limits are violated.
The RRTI justification conservatively uses an adiabatic heat-up rate to evaluate the component temperatures during the short-term configuration. The adiabatic methodology while technically accurate, is not a FSAR described methodology approved for short-term operations. However, the adiabatic heat-up methodology is an NRC approved methodology used in the Time to Boil calculations (FSAR 4.5.3) and HI-STORM Burial Under Debris (FSAR 4.6.2.5) evaluations. The FSAR describes the thermal model for short-term operation in Section 4.4.3, Test Model, as a FLUENT CFD program. Thus, requiring a 72.48 evaluation, justifying that the change of methodology is allowable under Part 72 regulation.
The RRTI conservatively uses an adiabatic heat up rate, which assumes no heat dissipates from the system. This is opposed to the FLUENT model which models air flow around the HI-TRAC to remove heat generated by the fuel. The RRTI evaluates a 20kW limit as acceptable for 24-hours and a 30 kW as acceptable for 12-hours. This is opposed to the FLUENT CFD models use of a 46.36 kW (HI-STORM FW system maximum heat load expected to last a few days) as stated in HI-2135813. The RRTI conservatively calculated component temperatures are then compared to FSAR Table 2.2.3 design temperature limits for HI-STORM FW components.
Allowances for a change in Methods of Evaluation (MOE) are allowed in accordance with LSAA-114-1000 (72.48 Resource Manual). Section 6.2.8.1 states that licensees or cask CoC holders can make changes to MOEs provided the results are essentially the same as, or more conservative than, previous results. Using an evaluation methodology that assumed no heat is dissipated from a system under specified fuel heat loads and time limits, reduces overall margin and is more conservative than previous results.
The use of administrative heat loads and time limits in Holtec procedure HPP-2226-300 R13 as evaluated using the adiabatic heat up methodology in RRTI-2858-004R0 in lieu of using the FLUENT software, provide results that are essentially the same as, or more conservative than,
Attachment E CPS 10 CFR 72.48 Summary Report Page 2 of 2 results that would have been calculated via the FLUENT software. Therefore, the change in use of a different conservative methodology does not constitute a departure from a method of valuation described in the FSAR and thus NRC approval is not required prior to implementation of HPP-2226-300 Rev. 13.
Attachment F CPS Electronic File Directory Structure Page 1 of 1 Directory Path File Name File Size USAR C:\\CPS USAR REV 23 001 Clinton USAR, Revision 23.pdf 816 MB OPERATIONAL REQUIREMENTS MANUAL C:\\CPS USAR REV 23 002 Clinton ORM, Revision 94.pdf 1.10 MB TECHNICAL SPECIFICATION BASES C:\\CPS USAR REV 23 003 Clinton TSB, Revision 22-09.pdf 1.80 MB