RS-11-023, Additional Information Related to License Amendment Request for Adoption of Technical Specifications Task Force-501: Difference between revisions
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{{#Wiki_filter:FXelor ;ene-at o-, 4300` | {{#Wiki_filter:FXelor ; ene-at o-, wwwexeloncc p.com Exe k n. | ||
Road Vdarrenville,'L 6()55; | 4300 `3vir ie'c': Road Nuclear Vdarrenville,'L 6()55; RS-1 1-023 10 CFR 50.90 February 24, 2011 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 | ||
==Subject:== | ==Subject:== | ||
| Line 25: | Line 25: | ||
==References:== | ==References:== | ||
: 1. Letter from J. L. Hansen (Exelon Generation Company, LLC (EGC)) to U. S. NRC, "License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, 'Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control,"' | |||
dated October 8, 2010 | |||
: 2. Letter from U. S. NRC to Mr. M. J. Pacilio (EGC), "Clinton Power Station, Unit No. 1 - Request for Additional Information Related to Request for Adoption of Technical Specification Task Force-501 (TAC No. ME4850)," | |||
dated December 7, 2010 | |||
: 3. Letter from P. R. Simpson (EGC) to U. S. NRC, "Response to Request for Additional Information Regarding License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, 'Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control,' (TAC No. ME4850)," dated January 6, 2011 | |||
: 4. Letter from U. S. NRC to Mr. M. J. Pacilio (EGC), "Clinton Power Station, Unit No. 1 - Request for Additional Information Related to Request for Adoption of Technical Specification Task Force-501 (TAC No. ME4850)," | |||
dated January 21, 2011 In Reference 1, Exelon Generation Company, LLC (EGC) requested an amendment to Appendix A, Technical Specifications (TS), of Facility Operating License No. NPF-62 for Clinton Power Station, Unit 1 (CPS). The proposed change modifies the CPS TS by implementing the guidance found in Technical Specifications Task Force (TSTF) Traveler TSTF-501, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control," Revision 1. | |||
February 24, 2011 U. S. Nuclear Regulatory Commission Page 2 In Reference 2, the NRC requested that EGC provide additional information in support of their review of Reference 1. The information requested in Reference 2 was provided in Reference 3. | February 24, 2011 U. S. Nuclear Regulatory Commission Page 2 In Reference 2, the NRC requested that EGC provide additional information in support of their review of Reference 1. The information requested in Reference 2 was provided in Reference 3. | ||
In Reference 4, the NRC requested that EGC provide additional information in support of their review of Reference 1. The NRC's request for additional information and the specific EGC responses are provided in the Attachment to this letter. | In Reference 4, the NRC requested that EGC provide additional information in support of their review of Reference 1. The NRC's request for additional information and the specific EGC responses are provided in the Attachment to this letter. | ||
| Line 35: | Line 39: | ||
This letter contains no new regulatory commitments. If you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819. | This letter contains no new regulatory commitments. If you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819. | ||
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 24th day of February, 2011. | I declare under penalty of perjury that the foregoing is true and correct. Executed on the 24th day of February, 2011. | ||
Je!rey/L.JWansen | Je!rey/L.JWansen Mana Licensing Exelon Generation Company, LLC | ||
==Attachment:== | ==Attachment:== | ||
Additional Information Supporting the Clinton Power Station Request for Adoption of Technical Specifications Task Force-501 | |||
ATTACHMENT Additional Information Supporting the Clinton Power Station Request for Adoption of Technical Specifications Task Force-501 Request No 1. Provide the expected change in accident loading for each emergency diesel generator (EDG) over the 7-day accident period. | |||
Provide the expected change in accident loading for each emergency diesel generator (EDG) over the 7 | |||
-day accident period. | |||
Request No. 1 Response: | Request No. 1 Response: | ||
In response to this request, Exelon Generation Company, LLC (EGC) postulated three scenarios for the seven | In response to this request, Exelon Generation Company, LLC (EGC) postulated three scenarios for the seven -day period following a worst case accident loss of offsite power (LOOP)/loss of coolant accident (LOCA). The operational sequence and single failure criteria described in Clinton Power Station, Unit 1 (CPS) Updated Safety Analysis Report (USAR) | ||
-day period following a worst case accident loss of offsite power (LOOP)/loss of coolant accident (LOCA).The operational sequence and single failure criteria described in Clinton Power Station, Unit 1 (CPS) | |||
Updated Safety Analysis Report (USAR) | |||
Section 6.3 and Tables 6.3-1, "Operational Sequence of Emergency Core Cooling Systems for Design-Basis Accident," 6.3-7, "Single Failure Evaluation," and 6.3-8, "ECCS Design Parameters for Clinton Power Station," were used in selecting the appropriate scenarios to evaluate. These scenarios were developed to demonstrate the extent of margin in the CPS emergency diesel generator (EDG) fuel oil storage requirements calculation. Descriptions of the three scenarios including the status of the major loads that were considered for each EDG and resulting EDG loading for each of the seven days following the accident described above are outlined in Tables 1 through 3 below. | Section 6.3 and Tables 6.3-1, "Operational Sequence of Emergency Core Cooling Systems for Design-Basis Accident," 6.3-7, "Single Failure Evaluation," and 6.3-8, "ECCS Design Parameters for Clinton Power Station," were used in selecting the appropriate scenarios to evaluate. These scenarios were developed to demonstrate the extent of margin in the CPS emergency diesel generator (EDG) fuel oil storage requirements calculation. Descriptions of the three scenarios including the status of the major loads that were considered for each EDG and resulting EDG loading for each of the seven days following the accident described above are outlined in Tables 1 through 3 below. | ||
Table 1: Scenario No. 1 - Seven Davs Following Accident Division/Com | Table 1: Scenario No. 1 - Seven Davs Following Accident Division/Com ponent Day 1 Day 2 _ Day 3 Day 4 Day 5 Day 6 Day 7 Residual Heat Removal A ON ON ON ON ON ON ON Division 1 Low Pressure Core S pray ON ON ON OFF OFF OFF OFF Division 1 EDG Loadin g kW 3760.9 3760.9 3760.9 2803.5 2803.5 2803.5 2803.5 Residual Heat Removal B OFF OFF OFF OFF OFF OFF OFF Division 2 Residual Heat Removal C OFF OFF OFF OFF OFF OFF OFF Division 2 EDG Loadin g kW 0 0 0 0 0 0 0 Hig h Pressure Core S pray ON OFF OFF ON ON ON ON Di v ision 3 Division 3 EDG Loadin g kW 2056 0 0 2056 2056 2056 2056 Table 2: Scenario No. 2 - Seven Davs Following Accident Division/Com onent Day 1 Day 2 Day 3 Day 4 Day 5 Da 6 Da 7 Residual Heat Removal A OFF OFF OFF OFF OFF OFF OFF Division 1 Low Pressure Core S pray OFF OFF OFF OFF OFF OFF OFF Division 1 EDG Loadin g kW 0 0 0 0 0 0 0 Residual Heat Removal B ON ON ON ON ON ON ON Division 2 Residual Heat Removal C ON ON ON OFF OFF OFF OFF Division 2 EDG Loadin g (kW) 3315.6 3315.6 3315.6 2839.8 2839.8 2839.8 2839.8 Hig h Pressure Core Spray ON OFF OFF ON ON ON ON Di v i s i on 3 Division 3 EDG Loadin g kW 2056 0 0 2056 2056 2056 2056 Table 3: Scenario No. 3 - Seven Davs Following Accident Division/Com onent Day 1 Day 2 Da y 3 Day 4 Day 5 Day 6 Day 7 Residual Heat Removal A ON ON ON ON ON ON ON Division 1 Low Pressure Core S pray ON OFF OFF OFF OFF OFF OFF Division 1 EDG Loadin g kW 3760.9 2803.5 2803.5 2803.5 2803.5 2803.5 2803.5 Residual Heat Removal B ON OFF OFF OFF OFF OFF OFF Division 2 Residual Heat Removal C ON ON ON ON ON ON ON Division 2 EDG Loadin g (kW) 3315.6 2839.8 2839.8 2839.8 2839.8 2839.8 2839.8 High Pressure Core S pray OFF OFF OFF OFF OFF OFF OFF Di v i s i on 3 Division 3 EDG Loadin g kW 0 0 0 0 0 0 0 Page 1 of 4 | ||
Request No 2. | |||
Provide the rate of fuel oil consumption for each EDG at full load conditions and at overload conditions. How are the rates of consumption established (recent testing, original equipment manufacturer data, etc.)? Have the EDG efficiencies been verified? | ATTACHMENT Additional Information Supporting the Clinton Power Station Request for Adoption of Technical Specifications Task Force-501 At CPS, fuel oil volume calculations are based on maximum post-LOCA loading applied to the entire seven-day time period for each EDG. This methodology was selected to allow a single load limit for each EDG to be provided to Operations personnel. Moreover, the CPS calculation methodology yields a bounding fuel oil volume requirement for each EDG; therefore, there are no limit restrictions on the load changes. This affords flexibility to Operations in managing EDG loads based on the individual load limits specified by the calculation. | ||
Request No 2. Provide the rate of fuel oil consumption for each EDG at full load conditions and at overload conditions. How are the rates of consumption established (recent testing, original equipment manufacturer data, etc.)? Have the EDG efficiencies been verified? Do the fuel oil volume calculations assume a linear change in the fuel oil consumption at different loading conditions? Are the fuel oil consumption rates used for Ultra Low Sulfur Diesel fuel? | |||
Request No. 2 Response: | Request No. 2 Response: | ||
The rate of fuel oil consumption for each EDG at full load and overload conditions can be found in Table 4 below. Full load is assumed to be maximum post-LOCA load and overload is the nameplate rating, as maximum post-LOCA loading never exceeds the nameplate value for each EDG.Table 4: EDG Fuel Oil Consumption at Full Load and Overload Con EDG Consumption at Full Load (lbs/kW-hr) | The rate of fuel oil consumption for each EDG at full load and overload conditions can be found in Table 4 below. Full load is assumed to be maximum post-LOCA load and overload is the nameplate rating, as maximum post-LOCA loading never exceeds the nameplate value for each EDG. | ||
Table 4: EDG Fuel Oil Consumption at Full Load and Overload Con EDG Consumption at Full Load Consumption at (lbs/kW-hr) overload Ibs/kW-hr Division 1 0.53 0.53 Division 2 0.532 0.53 Division 3 0.53 0.53 Rates of consumption are based on the vendor-guaranteed rates of consumption. CPS performed pre-operation testing to determine fuel consumption rates, which were lower than factory provided data. Consequently, the factory test data is used because the values are conservative, and determined using an accurate method and are the most reliable data available. | |||
CPS does not verify diesel efficiencies on an ongoing basis; however, the CPS EDG maintenance program has been developed from multiple sources including the engine manufacturer, owners' groups, industry, and site specific experience resulting in optimum engine performance, availability and reliability. Thus, assurance is provided that the CPS EDGs are maintained in a condition that ensures efficiencies are maintained. | CPS does not verify diesel efficiencies on an ongoing basis; however, the CPS EDG maintenance program has been developed from multiple sources including the engine manufacturer, owners' groups, industry, and site specific experience resulting in optimum engine performance, availability and reliability. Thus, assurance is provided that the CPS EDGs are maintained in a condition that ensures efficiencies are maintained. | ||
The guaranteed EDG fuel oil consumption rate provided by the vendor is 0.53 lbs/kW-hr at 100% of rated load, 0.54 lbs/kW-hr at 75% of rated load and 0.60 lbs/kW-hr at 50% of rated load.Since the consumption rates are non-linear, a polynomial chart was prepared from these values and used for the fuel oil consumption analysis. | The guaranteed EDG fuel oil consumption rate provided by the vendor is 0.53 lbs/kW-hr at 100% of rated load, 0.54 lbs/kW-hr at 75% of rated load and 0.60 lbs/kW-hr at 50% of rated load. Since the consumption rates are non-linear, a polynomial chart was prepared from these values and used for the fuel oil consumption analysis. | ||
Page 2 of 4 ATTACHMENT Additional Information Supporting the Clinton Power Station Request for Adoption of Technical Specifications Task Force-501 reduction in energy content identified in NRC Information Notice (IN) 2006-22," New Ultra-low | Page 2 of 4 | ||
Request No 3. | ATTACHMENT Additional Information Supporting the Clinton Power Station Request for Adoption of Technical Specifications Task Force-501 The consumption rate has been corrected in the consumption equation by using the 1.2% | ||
Does the Clinton Power Station fuel oil volume calculation method yield conservative results compared to the American National Standards Institute (ANSI) N195-1976 method (i.e., account for the 10 percent margin, account for the fuel oil volume consumed by testing) for each EDG?Request No. 3 Response: | reduction in energy content identified in NRC Information Notice (IN) 2006-22," New Ultra-low - | ||
Table 5 below describes the CPS stored fuel oil volume requirements considering the time | sulfur Diesel Fuel Oil Could Adversely Impact Diesel Engine Performance," dated October 12, 2006, for ultra-low sulfur diesel fuel. This approach is consistent with fuel manufacturer recommendations. | ||
Request No 3. Does the Clinton Power Station fuel oil volume calculation method yield conservative results compared to the American National Standards Institute (ANSI) N195-1976 method (i.e., account for the 10 percent margin, account for the fuel oil volume consumed by testing) for each EDG? | |||
Table 5: Comparison of the Clinton Power Station Stored Fuel Oil Volume Calculation Method to the ANSI Ni 95-1976 Method Required Stored Fuel Oil Based on Time-Fuel Oil De endent Loads ( | Request No. 3 Response: | ||
+T)Calculation Method | Table 5 below describes the CPS stored fuel oil volume requirements considering the time - | ||
Provide the amount of fuel oil volume consumed by testing (the value T in ANSI N195 | dependent loading provided in the response to Request No. 1, including fuel oil consumed by testing (i.e., T Value from ANSI N195-1976 Section 5.4) and 10% margin. Fuel consumption is calculated based on the worst-case loading of the three postulated scenarios that were developed in response to Request No. 1 above. This shows that there is margin to required stored fuel oil volume in the CPS calculation method and that the CPS method is conservative compared to the N195-1976 method for each EDG as shown in Table 5 below. | ||
-1976) for each EDG. | Table 5: Comparison of the Clinton Power Station Stored Fuel Oil Volume Calculation Method to the ANSI Ni 95-1976 Method Required Stored Fuel Oil Based on Time- Fuel Oil De endent Loads (gal) Required Stored Storage Fuel Oil According EDG Tank Time to the CPS 110% * (Time Dependent + T) Calculation Method Design Dependent (gal) Capacity (gal) | ||
Division 1 41274 46345 51000 54000 Division 2 39114 43896 45000 54000 Division 3 18684 21164 29500 36000 Page 3 of 4 | |||
ATTACHMENT Additional Information Supporting the Clinton Power Station Request for Adoption of Technical Specifications Task Force-501 Request No 4. Provide the amount of fuel oil volume consumed by testing (the value T in ANSI N195- 1976) for each EDG. | |||
Request No. 4 Response: | Request No. 4 Response: | ||
The monthly test performed for each EDG is approximately one hour at rated load and one hour | The monthly test performed for each EDG is approximately one hour at rated load and one hour at unloaded conditions. This is sufficient time to conclude the test. To provide a bounding value, the fuel oil consumption during testing was calculated using maximum post-LOCA loading for the duration of the two-hour test. The results of these calculations are provided in Table 6 below. | ||
Table 6: Fuel Oil Consumption During Testing (i.e. Tin ANSI N195-1976) for Each CPS EDG EDG T (gal) | |||
at unloaded conditions. This is sufficient time to conclude the test. To provide a bounding value, the fuel oil consumption during testing was calculated using maximum post-LOCA loading for the duration of the two-hour test. The results of these calculations are provided in Table 6 below. | Division 1 570 Division 2 502 Division 3 311 Page 4 of 4}} | ||
Table 6: Fuel Oil Consumption During Testing (i.e. Tin ANSI N195-1976) for Each CPS EDG EDG T (gal)Division 1 570 Division 2 502 Division 3 311 Page 4 of 4}} | |||
Revision as of 02:57, 13 November 2019
| ML110550579 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/24/2011 |
| From: | Hanson J Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-11-023, TAC ME4850 | |
| Download: ML110550579 (6) | |
Text
FXelor ; ene-at o-, wwwexeloncc p.com Exe k n.
4300 `3vir ie'c': Road Nuclear Vdarrenville,'L 6()55; RS-1 1-023 10 CFR 50.90 February 24, 2011 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
Subject:
Additional Information Related to License Amendment Request for Adoption of Technical Specifications Task Force-501 (TAC No. ME4850)
References:
- 1. Letter from J. L. Hansen (Exelon Generation Company, LLC (EGC)) to U. S. NRC, "License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, 'Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control,"'
dated October 8, 2010
- 2. Letter from U. S. NRC to Mr. M. J. Pacilio (EGC), "Clinton Power Station, Unit No. 1 - Request for Additional Information Related to Request for Adoption of Technical Specification Task Force-501 (TAC No. ME4850),"
dated December 7, 2010
- 3. Letter from P. R. Simpson (EGC) to U. S. NRC, "Response to Request for Additional Information Regarding License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, 'Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control,' (TAC No. ME4850)," dated January 6, 2011
- 4. Letter from U. S. NRC to Mr. M. J. Pacilio (EGC), "Clinton Power Station, Unit No. 1 - Request for Additional Information Related to Request for Adoption of Technical Specification Task Force-501 (TAC No. ME4850),"
dated January 21, 2011 In Reference 1, Exelon Generation Company, LLC (EGC) requested an amendment to Appendix A, Technical Specifications (TS), of Facility Operating License No. NPF-62 for Clinton Power Station, Unit 1 (CPS). The proposed change modifies the CPS TS by implementing the guidance found in Technical Specifications Task Force (TSTF) Traveler TSTF-501, "Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control," Revision 1.
February 24, 2011 U. S. Nuclear Regulatory Commission Page 2 In Reference 2, the NRC requested that EGC provide additional information in support of their review of Reference 1. The information requested in Reference 2 was provided in Reference 3.
In Reference 4, the NRC requested that EGC provide additional information in support of their review of Reference 1. The NRC's request for additional information and the specific EGC responses are provided in the Attachment to this letter.
The information provided in this letter does not affect the No Significant Hazards Consideration, or the Environmental Consideration provided in Attachment 1 of the original license amendment request as described in the Reference 1 submittal.
In accordance with 10 CFR 50.91(b), "State consultation," EGC is providing the State of Illinois with a copy of this letter and its attachment to the designated State Official.
This letter contains no new regulatory commitments. If you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 24th day of February, 2011.
Je!rey/L.JWansen Mana Licensing Exelon Generation Company, LLC
Attachment:
Additional Information Supporting the Clinton Power Station Request for Adoption of Technical Specifications Task Force-501
ATTACHMENT Additional Information Supporting the Clinton Power Station Request for Adoption of Technical Specifications Task Force-501 Request No 1. Provide the expected change in accident loading for each emergency diesel generator (EDG) over the 7-day accident period.
Request No. 1 Response:
In response to this request, Exelon Generation Company, LLC (EGC) postulated three scenarios for the seven -day period following a worst case accident loss of offsite power (LOOP)/loss of coolant accident (LOCA). The operational sequence and single failure criteria described in Clinton Power Station, Unit 1 (CPS) Updated Safety Analysis Report (USAR)
Section 6.3 and Tables 6.3-1, "Operational Sequence of Emergency Core Cooling Systems for Design-Basis Accident," 6.3-7, "Single Failure Evaluation," and 6.3-8, "ECCS Design Parameters for Clinton Power Station," were used in selecting the appropriate scenarios to evaluate. These scenarios were developed to demonstrate the extent of margin in the CPS emergency diesel generator (EDG) fuel oil storage requirements calculation. Descriptions of the three scenarios including the status of the major loads that were considered for each EDG and resulting EDG loading for each of the seven days following the accident described above are outlined in Tables 1 through 3 below.
Table 1: Scenario No. 1 - Seven Davs Following Accident Division/Com ponent Day 1 Day 2 _ Day 3 Day 4 Day 5 Day 6 Day 7 Residual Heat Removal A ON ON ON ON ON ON ON Division 1 Low Pressure Core S pray ON ON ON OFF OFF OFF OFF Division 1 EDG Loadin g kW 3760.9 3760.9 3760.9 2803.5 2803.5 2803.5 2803.5 Residual Heat Removal B OFF OFF OFF OFF OFF OFF OFF Division 2 Residual Heat Removal C OFF OFF OFF OFF OFF OFF OFF Division 2 EDG Loadin g kW 0 0 0 0 0 0 0 Hig h Pressure Core S pray ON OFF OFF ON ON ON ON Di v ision 3 Division 3 EDG Loadin g kW 2056 0 0 2056 2056 2056 2056 Table 2: Scenario No. 2 - Seven Davs Following Accident Division/Com onent Day 1 Day 2 Day 3 Day 4 Day 5 Da 6 Da 7 Residual Heat Removal A OFF OFF OFF OFF OFF OFF OFF Division 1 Low Pressure Core S pray OFF OFF OFF OFF OFF OFF OFF Division 1 EDG Loadin g kW 0 0 0 0 0 0 0 Residual Heat Removal B ON ON ON ON ON ON ON Division 2 Residual Heat Removal C ON ON ON OFF OFF OFF OFF Division 2 EDG Loadin g (kW) 3315.6 3315.6 3315.6 2839.8 2839.8 2839.8 2839.8 Hig h Pressure Core Spray ON OFF OFF ON ON ON ON Di v i s i on 3 Division 3 EDG Loadin g kW 2056 0 0 2056 2056 2056 2056 Table 3: Scenario No. 3 - Seven Davs Following Accident Division/Com onent Day 1 Day 2 Da y 3 Day 4 Day 5 Day 6 Day 7 Residual Heat Removal A ON ON ON ON ON ON ON Division 1 Low Pressure Core S pray ON OFF OFF OFF OFF OFF OFF Division 1 EDG Loadin g kW 3760.9 2803.5 2803.5 2803.5 2803.5 2803.5 2803.5 Residual Heat Removal B ON OFF OFF OFF OFF OFF OFF Division 2 Residual Heat Removal C ON ON ON ON ON ON ON Division 2 EDG Loadin g (kW) 3315.6 2839.8 2839.8 2839.8 2839.8 2839.8 2839.8 High Pressure Core S pray OFF OFF OFF OFF OFF OFF OFF Di v i s i on 3 Division 3 EDG Loadin g kW 0 0 0 0 0 0 0 Page 1 of 4
ATTACHMENT Additional Information Supporting the Clinton Power Station Request for Adoption of Technical Specifications Task Force-501 At CPS, fuel oil volume calculations are based on maximum post-LOCA loading applied to the entire seven-day time period for each EDG. This methodology was selected to allow a single load limit for each EDG to be provided to Operations personnel. Moreover, the CPS calculation methodology yields a bounding fuel oil volume requirement for each EDG; therefore, there are no limit restrictions on the load changes. This affords flexibility to Operations in managing EDG loads based on the individual load limits specified by the calculation.
Request No 2. Provide the rate of fuel oil consumption for each EDG at full load conditions and at overload conditions. How are the rates of consumption established (recent testing, original equipment manufacturer data, etc.)? Have the EDG efficiencies been verified? Do the fuel oil volume calculations assume a linear change in the fuel oil consumption at different loading conditions? Are the fuel oil consumption rates used for Ultra Low Sulfur Diesel fuel?
Request No. 2 Response:
The rate of fuel oil consumption for each EDG at full load and overload conditions can be found in Table 4 below. Full load is assumed to be maximum post-LOCA load and overload is the nameplate rating, as maximum post-LOCA loading never exceeds the nameplate value for each EDG.
Table 4: EDG Fuel Oil Consumption at Full Load and Overload Con EDG Consumption at Full Load Consumption at (lbs/kW-hr) overload Ibs/kW-hr Division 1 0.53 0.53 Division 2 0.532 0.53 Division 3 0.53 0.53 Rates of consumption are based on the vendor-guaranteed rates of consumption. CPS performed pre-operation testing to determine fuel consumption rates, which were lower than factory provided data. Consequently, the factory test data is used because the values are conservative, and determined using an accurate method and are the most reliable data available.
CPS does not verify diesel efficiencies on an ongoing basis; however, the CPS EDG maintenance program has been developed from multiple sources including the engine manufacturer, owners' groups, industry, and site specific experience resulting in optimum engine performance, availability and reliability. Thus, assurance is provided that the CPS EDGs are maintained in a condition that ensures efficiencies are maintained.
The guaranteed EDG fuel oil consumption rate provided by the vendor is 0.53 lbs/kW-hr at 100% of rated load, 0.54 lbs/kW-hr at 75% of rated load and 0.60 lbs/kW-hr at 50% of rated load. Since the consumption rates are non-linear, a polynomial chart was prepared from these values and used for the fuel oil consumption analysis.
Page 2 of 4
ATTACHMENT Additional Information Supporting the Clinton Power Station Request for Adoption of Technical Specifications Task Force-501 The consumption rate has been corrected in the consumption equation by using the 1.2%
reduction in energy content identified in NRC Information Notice (IN) 2006-22," New Ultra-low -
sulfur Diesel Fuel Oil Could Adversely Impact Diesel Engine Performance," dated October 12, 2006, for ultra-low sulfur diesel fuel. This approach is consistent with fuel manufacturer recommendations.
Request No 3. Does the Clinton Power Station fuel oil volume calculation method yield conservative results compared to the American National Standards Institute (ANSI) N195-1976 method (i.e., account for the 10 percent margin, account for the fuel oil volume consumed by testing) for each EDG?
Request No. 3 Response:
Table 5 below describes the CPS stored fuel oil volume requirements considering the time -
dependent loading provided in the response to Request No. 1, including fuel oil consumed by testing (i.e., T Value from ANSI N195-1976 Section 5.4) and 10% margin. Fuel consumption is calculated based on the worst-case loading of the three postulated scenarios that were developed in response to Request No. 1 above. This shows that there is margin to required stored fuel oil volume in the CPS calculation method and that the CPS method is conservative compared to the N195-1976 method for each EDG as shown in Table 5 below.
Table 5: Comparison of the Clinton Power Station Stored Fuel Oil Volume Calculation Method to the ANSI Ni 95-1976 Method Required Stored Fuel Oil Based on Time- Fuel Oil De endent Loads (gal) Required Stored Storage Fuel Oil According EDG Tank Time to the CPS 110% * (Time Dependent + T) Calculation Method Design Dependent (gal) Capacity (gal)
Division 1 41274 46345 51000 54000 Division 2 39114 43896 45000 54000 Division 3 18684 21164 29500 36000 Page 3 of 4
ATTACHMENT Additional Information Supporting the Clinton Power Station Request for Adoption of Technical Specifications Task Force-501 Request No 4. Provide the amount of fuel oil volume consumed by testing (the value T in ANSI N195- 1976) for each EDG.
Request No. 4 Response:
The monthly test performed for each EDG is approximately one hour at rated load and one hour at unloaded conditions. This is sufficient time to conclude the test. To provide a bounding value, the fuel oil consumption during testing was calculated using maximum post-LOCA loading for the duration of the two-hour test. The results of these calculations are provided in Table 6 below.
Table 6: Fuel Oil Consumption During Testing (i.e. Tin ANSI N195-1976) for Each CPS EDG EDG T (gal)
Division 1 570 Division 2 502 Division 3 311 Page 4 of 4