JAFP-20-0083, Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule

Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing

ML20346A025
Person / Time
Site:	FitzPatrick
Issue date:	12/11/2020
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-20-0083
Download: ML20346A025 (42)

Text

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 [[::JAF-20-0083|JAF-20-0083]] December 11, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

Application t o Revise Technical Specifications to Adopt TSTF-545, Revision 3, "TS lnservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing" Pursuant to 10 CFR 50.90, Exelon Generation Company, LLC (EGG) is submitting a request for an amendment to the Technical Specifications (TS) for James A. FitzPatrick Nuclear Power Plant (JAF). The proposed change revises the Technical Specifications (TS) to eliminate the Section 5.5, "Inservice Test Program." A new defined term, "Inservice Testing Program," is added to the TS Definitions section. This request is consistent with TSTF-545, Revision 3, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing."

The proposed change revises TS Section 5.5, or equivalent, "lnservice Test Program."

A new defined term, "INSERVICE TESTING PROGRAM," is added to the TS Definitions section. This request is consistent with TSTF-545, Revision 3, "TS lnservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing." provides a description and assessment of the proposed TS changes. provides the existing TS pages marked up to show the proposed changes. provides TS Bases pages marked up to show the associated TS Bases changes and is provided for information only.

Approval of the proposed amendments is requested by December 11, 2021. Once approved, the amendments shall be implemented within 90 days.

License Amendment Request To Revise Technical Specifications to Adopt TSTF-545, Revision 3 Docket No. DPR-59 December 11, 2020 Page 2 The proposed changes have been reviewed by the Plant Operations Review Committee.

There are no new commitments contained in this submittal.

Pursuant to 10 CFR 50.91 (b)(1), a copy of this License Amendment Request is being provided to the designated New York State official.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 11th day of December 2020.

If you have any questions regarding this submittal, please contact Enrique Villar at (610) 765-5736 Respectfully, David T. Gudger Senior Manager, Licensing Exelon Generation Company, LLC Attachments: 1. Provides a description and assessment of the proposed TS changes.

2. Provides the existing TS pages marked up to show the proposed changes.

3. Provides TS Bases pages marked up to show the associated TS Bases changes and is provided for information only.

cc: Regional Administrator - NRC Region I w/ attachments NRC Senior Resident Inspector - JAF NRC Project Manager, NRR - JAF A. L. Peterson, NYSERDA "

Attachment 1 Description and Assessment of the Proposed Technical Specifications Changes

1.0 DESCRIPTION

The proposed change revises the Technical Specifications (TS), Section 5.5, or equivalent, "Inservice Test (IST) Program," to remove requirements duplicated in American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), Case OMN-20, "Inservice Test Frequency." A new defined term, "INSERVICE TESTING PROGRAM," is added to TS Section 1.1, or equivalent, "Definitions."

The proposed change to the TS is consistent with Technical Specification Task Force (TSTF)-545, Revision 3, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing."

Revision 3 of RG 1.192 dated October 2019 lists OMN-20 in Table 2 Conditionally Acceptable OM Code Cases 2.1

ASSESSMENT 2.2

Applicability of Published Safety Evaluation Exelon Generation Company, LLC (EGC) has reviewed the model safety evaluation referred to in the Federal Register Notice of Availability dated March 28, 2016. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-545. EGC concluded that the justifications presented in TSTF-545, and the model safety evaluation prepared by the NRC staff is applicable to JAF and justify this amendment for the incorporation of the changes to each plants TS.

James A. FitzPatrick Nuclear Power Plant (JAF) was issued a construction permit on May 20, 1970, and the provisions of 10 CFR 50.55a(f)(3) are applicable.

2.3 Variations

Table 1 below identifies variations/deviations from the TSTF where the STS numbering is different from JAFs, or the SR is not included in the JAF TS.

Table 1 Variations from TSTF 545 BWR/4 markups to JAF technical Specifications DESCRIPTION APPLICABILITY TO JAF TECH. SPECS TSTF 545 BWR4 SRs Deletes Section 5.5.7 Inservice Testing Applicable to JAF; however, JAF will Program and re-numbers all the following deleted verbiage associated with section programs in the section 5.5.7 and annotate this section as not Used. The remaining program numbers will not be revised. These program numbers, including the Inservice Testing Section 5.0 Programs Program, are referenced in a multitude of and Manuals station procedures. By maintaining the current program numbering and references, excessive administrative burden to update station procedure references is avoided.

Attachment 1 Description and Assessment of the Proposed Technical Specifications Changes Pages 3 of 6 Verify equivalent leakage of each RCS PIV Not applicable to JAF. JAF does not have is 0.5 gpm per nominal inch of valve this SR.

SR 3.4.5.1 size up to a maximum of 5 gpm, at an RCS pressure [ ] and [ ] psig Verify each required ECCS pump develops the specified flow rate [against a system Not applicable to JAF. JAF does not have SR 3.5.2.5 head corresponding to the specified this SR.

reactor pressure Verify the isolation time of each power Applicable to JAF and incorporated; SR 3.6.1.3.6 operated automatic PCIV, [except for However, this SR is numbered SR MSIVs], is within limits 3.6.1.3.5 Applicable to JAF and incorporated; Verify the isolation time of each MSIV is SR 3.6.1.3.8 However, this SR is numbered SR

[2] seconds and [8] Seconds.

3.6.1.3.6

[ Verify each RHR pump develops a flow Applicable to JAF and incorporated; rate [400] gpm through the heat However, this SR is numbered SR SR 3.6.2.4.2 exchanger while operating in the 3.6.1.9.2 suppression pool spray mode.

Verify the isolation time of each power Not applicable to JAF. JAF does not have SR 3.6.4.2.2 operated, automatic SCIV is within limits this SR Table 2 below identifies JAF plant specific SRs that are not identify in the TSTF, but that clearly fall within the scope of the TSTF but are:

Table 2 JAF Technical Specifications SRs within the scope of TSTF 545 but not included in the approved TSTF DESCRIPTION COMMENTS JAF TS SR The current SR Frequency is in accordance with Inservice Testing Cycle each SDV vent and drain valve to program, and it will be changed to in SR 3.1.8.2 the fully closed and fully open position. accordance with the INSERVICE TESTING PROGRAM The current SR Frequency is in accordance with Inservice Testing Each required S/RV is capable of being program, and it will be changed to in SR 3.4.3.2 closed accordance with the INSERVICE TESTING PROGRAM The current SR Frequency is in accordance with Inservice Testing SR 3.5.1.8 Verify reactor pressure 1040 psig. program, and it will be changed to in accordance with the INSERVICE TESTING PROGRAM The current SR Frequency is in accordance with Inservice Testing Verify each required ADS valve is capable program, and it will be changed to in SR 3.5.1.13 of being opened. accordance with the INSERVICE TESTING PROGRAM The current SR Frequency is in accordance with Inservice Testing Verify each reactor instrumentation line program, and it will be changed to in SR 3.6.1.3.8 EFCV accordance with the INSERVICE TESTING PROGRAM

Attachment 1 Description and Assessment of the Proposed Technical Specifications Changes Pages 4 of 6 The current SR Frequency is in accordance with Inservice Testing Perform a functional test of each vacuum program, and it will be changed to in SR 3.6.1.6.2 breaker accordance with the INSERVICE TESTING PROGRAM The current SR Frequency is in accordance with Inservice Testing Perform a functional test of each vacuum program, and it will be changed to in SR 3.6.1.7.2 breaker accordance with the INSERVICE TESTING PROGRAM Has two references to the IST They are changed to INSERVICE TS Bases SR 3.4.3.2 TESTING PROGRAM Program Verify each RHR pump develops a flow rate > [7700] gpm through the associated SR 3.6.2.3.2 heat exchanger while operating in the suppression pool cooling mode.

..Verification during reactor start up prior Inservice Testing Program will be changed TS Bases SR 3.5.1.6 to reaching >25% RTP is an exception to to INSERVICE TESTING PROGRAM the normal Inservice Testing Program.

Inservice Testing Program is changed TS Bases SR It partially states as part of the to INSERVICE TESTING PROGRAM 3.5.1.13 Inservice Testing Program.

It partially states The associated Inservice Testing (IST) Program is TS Bases page stroke time of each automatic PCIV is changed to INSERVICE TESTING B3.6.1.3-3 included in the Inservice Testing (IST) PROGRAM Program It partially states ESW pumps is IST Program is changed to INSERVICE TS Bases page based on measured performance TESTING PROGRAM B3.7.2-3: remaining within allowable IST Program acceptance criteria Exelon has concluded that the differences described above are administrative in nature and do not affect the applicability of TSTF- 545 or the associated model SE.

3.2 No Significant Hazards Consideration

Exelon Generation Company, LLC (EGC) requests adoption of the Technical Specification (TS) changes described in TSTF-545, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," which is an approved change to the TS.

The proposed change revises the TS Chapter 5, or equivalent, "Administrative Controls," Section 5.5 "Programs and Manuals," to revise the "Inservice Testing (IST) Program" specification. Requirements in the IST Program that are duplicative of requirements in the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code, as clarified by Code Case OMN-20, "Inservice Test Frequency," are deleted. Other requirements in Section 5.5, or equivalent, are eliminated because the Nuclear Regulatory Commission (NRC) has determined their appearance in the TS is contrary to regulations. A

Attachment 1 Description and Assessment of the Proposed Technical Specifications Changes Pages 5 of 6 new defined term, "INSERVICE TESTING PROGRAM," is added, which references the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, paragraph 50.55a(f). EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

Performance of inservice testing is not an initiator to any accident previously evaluated. As a result, the probability of occurrence of an accident is not significantly affected by the proposed change. Inservice test frequencies under Code Case OMN-20 are equivalent to the current testing period allowed by the TS with the exception that testing frequencies greater than two (2) years may be extended by up to six (6) months to facilitate test scheduling and consideration of plant operating conditions that may not be suitable for performance of the required testing. The testing frequency extension will not affect the ability of the components to mitigate any accident previously evaluated as the components are required to be operable during the testing period extension. Performance of inservice tests utilizing the allowances in OMN-20 will not significantly affect the reliability of the tested components. As a result, the availability of the affected components, as well as their ability to mitigate the consequences of accidents previously evaluated, is not affected.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not alter the design or configuration of the plant. The proposed change does not involve a physical alteration of the plant; no new or different kind of equipment will be installed. The proposed change does not alter the types of inservice testing performed. In most cases, the frequency of inservice testing is unchanged. However, the frequency of testing would not result in a new or different kind of accident from any previously evaluated since the testing methods are not altered.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change eliminates some requirements from the TS in lieu of requirements in the ASME Code, as modified by use of Code Case OMN-20. Compliance with the ASME Code is required by 10 CFR 50.55a. The proposed change also allows inservice tests with frequencies

Attachment 1 Description and Assessment of the Proposed Technical Specifications Changes Pages 6 of 6 greater than two years to be extended by six months to facilitate test scheduling and consideration of plant operating conditions that may not be suitable for performance of the required testing. The testing frequency extension will not affect the ability of the components to respond to an accident as the components are required to be operable during the testing period extension. The proposed change will eliminate the existing TS SR 3.0.3, or equivalent, allowance to defer performance of missed inservice tests up to the duration of the specified testing frequency, and instead will require an assessment of the missed test on equipment operability. This assessment will consider the effect on a margin of safety (i.e., equipment operability). Should the component be inoperable, the TS provide actions to ensure that the margin of safety is protected. The proposed change also eliminates a statement that nothing in the ASME Code should be construed to supersede the requirements of any TS. The NRC has determined that statement to be incorrect. However, elimination of the statement will have no effect on plant operation or safety.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, EGC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.