ML23031A297

Issuance of Amendment No. 248 Adoption of TSTF-269, Revision 2

ML23031A297
Person / Time
Site:	Clinton
Issue date:	03/01/2023
From:	Joel Wiebe NRC/NRR/DORL/LPL3
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
EPID L-2022-LLA-0077
Download: ML23031A297 (1)

Text

March 1, 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, UN IT NO. 1 - ISSUANCE OF AMENDMENT NO. 248 RE: ADOPTION OF TSTF-269, REVISION 2 (EPID L-2022-LLA-0077)

Dear Mr. Rhoades:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 248 to Facility Operating License No. NPF-62 for the Clinton Power Station, Unit No. 1. The amendment is in response to your application dated May 24, 2022.

The amendment is consistent with NRC-approved Technical Specification Task Force (TSTF)

Traveler 269-A, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves. Specifically, the proposed chan ge modifies technical specification requirements for repetitive verification of the status of locked, sealed, or secured components, to allow the verification to be by administrative means.

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. 248 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. 248 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 May 24, 2022, 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. 248, 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.

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

Robert F. Kuntz, Acting 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: March 1, 2023

ATTACHMENT TO LICENSE AMENDMENT NO. 248

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

3.6-11 3.6-11 3.6-13 3.6-13 3.6-48 3.6-48 3.6-62 3.6-62

(4) Constellation Energy Generation, LLC, 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, LLC, 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, LLC, 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, LLC, 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, LLC 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. 248, 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. 248 PCIVs 3.6.1.3

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. (continued) A.2 ---------NOTES---------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per penetration flow path 31 days is isolated. following isolation for isolation devices outside primary containment, drywell, and steam tunnel

AND

Prior to entering MODE 2 or 3 from MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment, drywell, or steam tunnel

(continued)

CLINTON 3.6-11 Amendment No. 248 PCIVs 3.6.1.3

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

D. One or more D.1 Isolate the affected 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> penetration flow paths penetration flow with one or more path by use of at OR primary containment least one closed and purge valves not de-activated In accordance within purge valve automatic valve, with the Risk leakage limits. closed manual valve, Informed or blind flange. Completion Time Program

AND

D.2 ---------NOTES----------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 penetration flow path days following is isolated. isolation for isolation devices outside primary containment

AND

Prior to entering MODE 2 or 3 from MODE 4 if not performed within the previous 92 days for isolation devices inside primary containment AND (continued)

CLINTON 3.6-13 Amendment No. 248 SCIDs 3.6.4.2

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

A. One or more A.1 Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> penetration flow paths penetration flow path with one SCID by use of at least inoperable. one closed and de-activated automatic damper, closed manual valve or damper, or blind flange.

AND

A.2 --------NOTES---------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per penetration flow path 31 days is isolated.

B. One or more B.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> penetration flow paths penetration flow path with two SCIDs by use of at least inoperable. one closed and de-activated automatic damper, closed manual valve or damper, or blind flange.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A AND or B not met in MODE 1, 2, or 3. C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

(continued)

CLINTON 3.6-48 Amendment No. 24802200 Drywell Isolation Valves 3.6.5.3

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

A. One or more A.1 Isolate the affected 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> penetration flow paths penetration flow path with one required by use of at least OR drywell isolation one closed and de-valve inoperable. activated automatic In accordance valve, closed manual with the Risk valve, blind flange, Informed or check valve with Completion Time flow through the Program valve secured.

AND

A.2 --------NOTES---------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Prior to penetration flow path entering MODE 2 is isolated. or 3 from MODE 4, if not performed within the previous 92 days

(continued)

CLINTON 3.6-62 Amendment No. 248224838 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

RELATED TO AMENDMENT NO. 248 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 license amendment request (LAR) dated May 24, 2022 (Reference 1), Constellation Energy Generation, LLC (the licensee), requested changes to the technical specifications (TSs) for the Clinton Power Station, Unit 1 (CPS).

The LAR proposes to revise TS 3.6.1.3, Primary Containment Isolation Valves (PCIVs),

Required Actions A.2 and D.2, TS 3.6.4.2, Secondary Containment Isolation Dampers (SCIDs), Required Action A.2, and TS 3.6.5.3, Drywell Isolation Valves, Required Action A.2, to add a note to each required action to allow isolation devices that are locked, sealed, or otherwise secured to be verified by use of administrative means. The licensee stated that these changes are consistent with Technical Specification Task Force (TSTF) Traveler TSTF-269-A, Revision 2, (Reference 2). The U.S. Nuclear Regulatory Commission (NRC or the Commission) approved TSTF-269-A, Revision 2, in a letter dated July 26, 1999 (Reference 3).

2.0 REGULATORY EVALUATION

2.1 Description of the Proposed TS Changes

The proposed change to TS 3.6.1.3 is to add the following note under Required Actions A.2 and D.2:

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

The proposed change to TS 3.6.4.2 is to add the following note under Required Action A.2:

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Enclosure 2

The proposed change to TS 3.6.5.3 is to add the following note under Required Action A.2:

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

In addition, the NOTE for these four required actions is proposed to be revised to NOTES, and the existing note, Isolation devices in high radiation areas may be verified by use of administrative means, is proposed to be renumbered as Note 1.

The licensee also proposed the following variations to TSTF-269-A, Rev 2:

The CPS TS do not contain a Condition equivalent to TS 3.6.1.3 Condition C in TSTF-269-A. Therefore, that change is not applicable to CPS.

TSTF-269-A identifies a change to TS 3.6.1.3 Required Action E.2. The equivalent Required Action in the CPS TS is D.2.

The licensee stated that these variations do not affect the applicability of TSTF-269-A to CPS.

2.2 Regulatory Requirements and Guidance

The regulatory requirements related to the content of the TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, Technical specifications, which requires that the TSs include items in five specific categories. These categories include: (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls. More specifically, 10 CFR 50.36(c)(2)(i) states, in part, that, When 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. Section 50.36 of 10 CFR does not specify which remedial actions are required or how quickly they must be completed.

The NRC staff used Revision 5.0 of NUREG-1434, Standard Technical Specifications [STS],

General Electric BWR/6 Plants, Volume 1 (Reference 4), Specifications, and NUREG-1434, Standard Technical Specifications, General Electric BWR/6 Plants, Volume 2, Bases (Reference 5) in its review of the TS changes proposed for CPS.

3.0 TECHNICAL EVALUATION

TSTF-269-A, Revision 2, revised STS 3.6.1.3, Primary Containment Isolation Valves (PCIVs),

Required Actions A.2, C.2, and E.2, STS 3.6.4.2, Secondary Containment Isolation Valves (SCIVs), Required Action A.2, and STS 3.6.5.3, Drywell Isolation Valves, Action A.2, by adding notes that isolation devices that are locked, sealed, or otherwise secured, may be verified by use of administrative means.

The NRC staff has reviewed the proposed changes to TSs 3.6.1.3, 3.6.4.2, and 3.6.5.3, and Reference 3, and has determined that verification of isolation valves and dampers that are locked, sealed, or otherwise secured using administrative means have proven to be adequate to

ensure the devices are maintained in the positions required by the plant safety analyses when primary and secondary containment is required to be operable.

Periodic verification is required for a penetration with an inoperable isolation device in order to detect and correct inadvertent repositioning of the isolation device. Because the purpose of locking, sealing, or securing components, is to prevent inadvertent repositioning, the licensee proposed that periodic reverification should be a verification of the administrative control that ensures that the component remains in the required state.

TS LCO 3.6.1.3 states, Each PCIV shall be OPERABLE. TS LCO 3.6.4.2 states, Each SCID shall be OPERABLE. TS 3.6.5.3 states, One drywell isolation valve in each drywell penetration flow path shall be OPERABLE, except for the drywell vent and purge penetrations in which two drywell isolation valves shall be OPERABLE. The OPERABILITY requirements for isolation devices ensure that components are capable of performing their safety functions within the time limits assumed in the safety analyses.

It is reasonable to assume that the initial establishment of component status (e.g., isolation valves closed) was performed correctly. Subsequent verifications of the component status are intended to ensure the component has not been inadvertently repositioned. Given that the function of locking, sealing, or securing components is to ensure the same avoidance of inadvertent repositioning, the staff finds that periodic reverification using administrative means that ensure that the component remains in the required state is acceptable. It is unnecessary to remove the lock, seal, or other means of securing the component solely to perform an active verification of the required state. Verification of the inoperable containment penetrations using administrative means ensures the components will continue to be isolated, and thus, perform their isolation function. In addition, the proposed change does not involve a physical alteration to the plant (i.e., no new or different type of equipment will be installed) or a change to the methods governing normal plant operation.

Additionally, the NRC staff concludes that the re quirements of 10 CFR 50.36(c)(2) will continue to be met because the minimum performance level of equipment needed for safe operation of the facility is contained in the LCO, and the appropriate remedial actions are specified if the LCO is not met.

Based on the above, the NRC staff concludes that the change is consistent with TSTF-269-A, Rev. 2 because administrative controls for isolation devices have proven to be adequate to ensure the devices are maintained in the positions required by the plant safety analyses. In addition, the NRC staff determined the licensees proposed variations do not affect the applicability of TSTF-269-A, Revision 2, to the proposed license amendments because the equivalent of TS 3.6.1.3 Condition C discussed in TSTF-269-A, Revision 2, does not appear in the CPS TSs and the equivalent of TS 3.6.1.3 Condition E.2 discussed in TSTF-269-A, Revision 2, is Condition D.2 in the CPS TS. Therefore, the NRC staff finds the proposed changes to TSs 3.6.3.1, 3.6.4.2, and 3.6.5.3, are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Illinois State official was notified of the proposed issuance of the amendment on January 31, 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 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 individual 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 15, 2022 (87 FR 42508), 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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Simpson, Patrick R., Constellation Energy Generation, LLC, letter to U.S. Nuclear Regulatory Commission, Request for License Amendment to Adopt TSTF-269, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves, dated May 24, 2022 (Agencywide Documents A ccess and Management System (ADAMS)

Accession No. ML22144A236).

2. Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF 269, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves, dated June 27, 1999 (ML040620100).

3. Beckner, William D., U.S. Nuclear Regulatory Commission, letter to Davis, James, Nuclear Energy Institute, dated July 26, 1999 (ML19067A141).

4. U.S. Nuclear Regulatory Commission, NUREG-1434, Standard Technical Specifications, General Electric BWR/6 Plants, Volume 1, Specifications, Revision 5.0, dated September 2021 (ML21271A582).

5. U.S. Nuclear Regulatory Commission, NUREG-1434, Standard Technical Specifications, General Electric BWR/6 Plants, Volume 2, Bases, Revision 5.0, dated September 2021 (ML21271A596).

Principal Contributor: Steve Smith

Date of issuance: March 1, 2023

ML23031A297 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/STSB/BC OGC-NLO NAME JWiebe SRohrer VCusumano JEzell DATE 1/31/2023 2/1/2023 1/30/2023 2/14/2023 OFFICE NRR/DORL/LPL3/BC(A) NRR/DORL/LPL3/PM NAME RKuntz JWiebe DATE 3/1/2023 3/1/2023