ML021130692

& Three Mile Island Unit 1, License Amendment Request, Relocate Emergency Diesel Generator Maintenance Inspection Requirements

ML021130692
Person / Time
Site:	Oyster Creek, Three Mile Island, Limerick
Issue date:	04/10/2002
From:	Gallagher M Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML021130692 (22)

Text

Exel n,.

Exelon Nuclear www.exeloncorp.com Nuclear 20o Exelon Way Kennett Square, PA 19348 10 CFR 50.90 April 10, 2002 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Oyster Creek Generating Station Facility Operating License No. DPR-16 NRC Docket No. 50-219 Three Mile Island, Unit 1 Facility Operating License No. DPR-50 NRC Docket No. 50-289

SUBJECT:

License Amendment Request Technical Specifications Changes to Relocate Emergency Diesel Generator Maintenance Inspection Requirements Pursuant to 10 CFR 50.90, Exelon Generation Company, LLC and AmerGen Energy Company, LLC are requesting changes to Technical Specifications (TS), Appendix A of the facility operating licenses listed above.

The proposed administrative changes will relocate Emergency Diesel Generator (EDG) maintenance inspection requirements from the TS to licensee-controlled documents, i.e., the Updated Final Safety Analysis Report or Technical Requirements Manual, as appropriate, either of which are controlled in accordance with the requirements of 10 CFR 50.59. This relocation will facilitate future implementation of performance centered maintenance under the Exelon and AmerGen Maintenance Rule Programs in accordance with 10 CFR 50.65, which will provide for evaluation of the appropriate elements of the vendor endorsed Owners' Group Maintenance Program.

This amendment request is subdivided as follows:

1. Attachment A provides an evaluation of the proposed changes in this License Amendment Request.

2. Attachment B provides the marked-up TS pages indicating the proposed changes for the respective stations.

3. Attachment C provides information supporting a finding of No Significant Hazards Consideration using the standards in 10 CFR 50.92, "Issuance of amendment," paragraph (c).

License Amendment Request Docket Nos. 50-219, 289, 352, 353 April 10, 2002 Page 2

4. Attachment D provides information supporting an Environmental Assessment.

Exelon Generation Company, LLC, and AmerGen Energy Company, LLC request approval of the proposed amendments by April, 2003. Once approved, this amendment shall be implemented within 30 days of issuance.

Additionally, there are no commitments contained within this letter.

The proposed changes have been reviewed by the Plant Operations Review Committee of each respective station, and approved by the Nuclear Safety Review Board.

If you have any questions or require additional information, please contact Glenn Stewart at (610) 765-5529.

I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, Executed on 0 0'-/

OZ Michael P. Gallagher Director, Licensing & Regulatory Affairs Mid-Atlantic Regional Operating Group Attachments: A. Description and Safety Analysis for Proposed Changes B. Technical Specifications Marked-up Pages C. No Significant Hazards Consideration D. Environmental Assessment cc: Regional Administrator - NRC Region I w/e ttachments Generating Station 3)

NRC Senior Resident Inspector - Limerick NRC Senior Resident Inspector - Oyster Creek Generating Station NRC Senior Resident Inspector - Three Mile Island, Unit 1 NRC Project Manager, NRR - Limerick Generating Station it NRC Project Manager, NRR - Oyster Creek Generating Station

&I NRC Project Manager, NRR - Three Mile Island, Unit 1 Director, Bureau of Nuclear Engineering, New Jersey Department cc of Environmental Protection Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, Dauphin County, PA It Mayor of Lacey Township, Forked River, NJ

Attachment A License Amendment Request Docket Nos. 50-219, 50-289, 50-352, and 50-353 DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES

License Amendment Request Docket Nos. 50-219, 289, 352, 353 Attachment A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES A.

SUMMARY

OF PROPOSED CHANGES In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (i.e., Exelon) and AmerGen Energy Company, LLC (i.e., AmerGen) are requesting changes to Technical Specifications (TS), Appendix A of Facility Operating License Nos. NPF-39, NPF-85, DPR-16, and DPR-50 for Limerick Generating Station (LGS), Units 1 and 2, Oyster Creek Generating Station (OCGS), and Three Mile Island, Unit 1 (TMI Unit 1), respectively.

The proposed changes will remove the current Technical Specification (TS) requirements for Emergency Diesel Generator (EDG) 24 month maintenance inspections and relocate these requirements to licensee-controlled documents, i.e., the Updated Final Safety Analysis Report or Technical Requirements Manual, as appropriate, either of which are controlled in accordance with the requirements of 10 CFR 50.59. A complete description of the proposed changes is given in Section D, "Description of the Proposed Changes," of this Attachment. Attachments B-1 through B-3 provide the marked-up TS pages indicating the proposed changes for the respective stations.

Please note that the relocation of the maintenance inspection requirements for EDGs to licensee-controlled documents was generically approved by the NRC in NUREG-1430, "Standard Technical Specifications, Babcock and Wilcox Plants," and NUREG-1 433, "Standard Technical Specifications, General Electric Plants (BWR/4)." Similar TS changes were previously approved by the NRC for the following Exelon Nuclear station through conversion to the improved Standard Technical Specifications (STS): Peach Bottom Atomic Power Station, Units 2 and 3. In addition, similar TS changes were approved by the NRC for the following Exelon Nuclear stations prior to their conversion to improved STS through the following site specific license amendments: Clinton Power Station, Unit 1, Amendment No. 87, approved January 31, 1994; LaSalle County Station, Units 1 and 2, Amendment Nos. 109 and 94, respectively, approved February 16, 1996; Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, Amendment Nos. 79 and 71, respectively, approved February 16, 1996; Dresden Nuclear Power Station, Units 2 and 3, Amendment Nos. 150 and 145, respectively, approved June 28, 1996; and Quad Cities Nuclear Power Station, Units 1 and 2, Amendment Nos. 171 and 167, respectively, approved June 28, 1996.

B. DESCRIPTION OF THE CURRENT REQUIREMENTS The following section describes the current licensing basis requirements for which a change is proposed.

1. Limerick Generating Station LGS has separate TS for Unit 1 and Unit 2; however, the specifications noted below are identical for both units.

A-1

License Amendment Request Docket Nos. 50-219, 289, 352, 353 Attachment A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES TS Section 3/4.8, "Electrical Power Systems," Specification 4.8.1.1.2.e.1 currently states:

Every 24 months subjecting the diesel to an inspection in accordancewith procedures preparedin conjunction with the FairbanksMorse Owners Group recommendations and its manufacturersrecommendationsfor this class of standby service.

2. Oyster Creek Generating Station TS Section 4.7, "Auxiliary Electrical Power", Specification 4.7.A.3 currently states:

Each diesel generatorshall be given a thorough inspection at least once per 24 months.

TS Section 4.7 Bases contained on page 4.7-4 currently state:

Thorough inspections will detect any signs of wear long before failure.

3. Three Mile Island, Unit 1 TS Section 4.6, "Emergency Power System Periodic Tests", Specification 4.6.1.c currently states:

Each diesel generatorshall be given an inspection every 24 months (with a 25%

allowable graceperiod)in accordancewith procedurespreparedin conjunction with the applicable recommendationsof the FairbanksMorse Owners Group and those of the manufacturerfor this class of stand-by service.

C. BASES FOR THE CURRENT REQUIREMENTS The Code of Federal Regulations, 10 CFR 50.36(c)(2)(ii) contains specific criteria on the establishment of Limiting Conditions for Operation (LCO) in the unit specific Technical Specifications. The EDGs constitute a system, structure, or component which is part of the primary success path for mitigating a design basis accident with a loss of offsite power. The TS identify the LCOs for the EDGs, and establish the surveillance requirements for periodic testing.

Besides testing to ensure LCO limits are met, the TS were also originally issued with a surveillance requirement for the periodic inspection of the EDGs.

The wording that exists in the current TS requirements for periodic EDG inspections are based on NRC endorsed industry standards to ensure that the licensee is performing the necessary EDG maintenance and inspections. In practice, this EDG maintenance is performed in accordance with the Exelon and AmerGen 10CFR50.65 Maintenance Rule Programs, using procedures prepared in conjunction with the programs developed by the various EDG owners' group maintenance organizations and endorsed by the EDG manufacturer.

A-2

License Amendment Request Docket Nos. 50-219, 289, 352, 353 Attachment A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES D. DESCRIPTION OF THE PROPOSED CHANGES The following section describes the proposed administrative changes to the TS requirements.

1. Limerick Generating Station LGS has separate TS for Unit 1 and Unit 2, however, the proposed change is identical for both units.

TS Section 3/4.8, "Electrical Power Systems," Specification 4.8.1.1.2.e.1 is being deleted and the requirement to perform EDG inspections is being relocated to licensee-controlled documents.

2. Oyster Creek Generating Station TS Section 4.7, "Auxiliary Electrical Power", Specification 4.7.A.3 and the associated wording in the TS Bases are being deleted and the requirement to perform EDG inspections is being relocated to licensee-controlled documents.

3. Three Mile Island, Unit 1 TS Section 4.6, "Emergency Power System Periodic Tests", Specification 4.6.1.c is being deleted and the requirement to perform EDG inspections is being relocated to licensee controlled documents.

E. NEED FOR REVISION OF THE REQUIREMENTS We request that the NRC review and approve the proposed TS changes to relocate requirements regarding the periodic maintenance inspections of the EDGs to licensee-controlled documents.

Although currently in the TS, the EDG inspection is a preventive maintenance requirement that is implemented through the Exelon and AmerGen 10 CFR 50.65 Maintenance Rule Programs.

This requirement is oriented toward long term EDG reliability, and does not have an immediate impact on EDG operability. EDG operability is verified by the surveillance requirements that will continue to be maintained in TS. Any proposed changes to this inspection requirement must currently receive prior NRC review and approval. The proposed TS changes will facilitate future EDG inspection program changes by Exelon or AmerGen that are determined to be appropriate by the Exelon or AmerGen 10 CFR 50.65 Maintenance Rule Programs. Such changes would be performed under the appropriate regulatory controls, e.g., 10 CFR 50.59.

A-3

License Amendment Request Docket Nos. 50-219, 289, 352, 353 Attachment A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES F. SAFETY ANALYSES OF THE PROPOSED CHANGES As previously noted, the proposed changes delete the current Technical Specification (TS) requirements for Emergency Diesel Generator (EDG) maintenance inspections and relocate the requirements to licensee-controlled documents, i.e., the Updated Final Safety Analysis Report or Technical Requirements Manual, as appropriate, either of which are controlled in accordance with the requirements of 10 CFR 50.59.

On July 22, 1993, the NRC issued the "NRC Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (Final Policy Statement) (58 FR 39132) which provided guidance for evaluating the required scope of the TS, and defined four specific criteria to be used in determining which of the limiting conditions for operation should remain in TS.

On July 19, 1995, 10 CFR 50.36 was revised to incorporate the four specific TS content criteria described in the Final Policy Statement into Section 36(c)(2)(ii) of 10 CFR Part 50 (60 FR 36953). As indicated in the Statements of Consideration for the revised rule, the NRC recognized that the four criteria focus on the technical requirements for features of controlling importance to safety. However, since many of the requirements are of significance to the health and safety of the public, the revised rule reflects the subjective statement of the purpose of TS expressed by the Atomic Safety and Licensing Appeal Board in PortlandGeneral Electric Company (Trojan Nuclear Plant), ALAB-531, 9 NRC 263 (1979). There, the Appeal Board stated:

"...technical specifications are to be reserved for those ... conditions or limitations upon reactor operation ... necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."

Both the Final Policy Statement and the Statements of Consideration for the revised 10 CFR 50.36 rule indicate that TS requirements that do not satisfy or fall within any of the four criteria may be relocated to appropriate licensee-controlled documents. Further, other details in the TS which do not meet the criteria may also be relocated, such as procedural details of system operation, procedural details for action and surveillance requirement performance, and preventive maintenance requirements. Such detailed information is not necessary to ensure the effectiveness of the TS, as noted by the above Atomic Safety and Licensing Appeal Board decision.

The EDG inspection is a preventive maintenance activity that is oriented toward long term EDG reliability, and does not have an immediate impact on EDG operability. EDG operability is verified by the surveillance requirements that will continue to be maintained in TS, e.g., the TS requirements that ensure proper EDG starting, timing, loading, and sequencing will not be affected by the proposed change. Therefore, in accordance with the NRC Final Policy Statement and the revised 10 CFR 50.36 rule, the EDG inspection requirement is not required to be included in TS.

The relocation of the maintenance inspection requirements for EDGs to licensee-controlled documents was generically approved by the NRC in NUREG-1430, "Standard Technical A-4

License Amendment Request Docket Nos. 50-219, 289, 352, 353 Attachment A DESCRIPTION AND SAFETY ANALYSIS FOR PROPOSED CHANGES Specifications, Babcock and Wilcox Plants," and NUREG-1433, "Standard Technical Specifications, General Electric Plants (BWR/4)," which are consistent with the NRC Final Policy Statement and the revised 10 CFR 50.36 rule. Similar TS changes were previously approved by the NRC for the following Exelon Nuclear station through conversion to the improved Standard Technical Specifications (STS): Peach Bottom Atomic Power Station, Units 2 and 3.

In addition, similar TS changes were approved by the NRC for the following Exelon Nuclear stations prior to their conversion to improved STS through the following site-specific license amendments: Clinton Power Station, Unit 1, Amendment No. 87, approved January 31, 1994; LaSalle County Station, Units 1 and 2, Amendment Nos. 109 and 94, respectively, approved February 16, 1996; Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, Amendment Nos. 79 and 71, respectively, approved February 16, 1996; Dresden Nuclear Power Station, Units 2 and 3, Amendment Nos. 150 and 145, respectively, approved June 28, 1996; and Quad Cities Nuclear Power Station, Units 1 and 2, Amendment Nos. 171 and 167, respectively, approved June 28, 1996. The relocation proposed herein furthers the commonality of operating practices throughout Exelon Nuclear and AmerGen.

The proposed TS changes are administrative in nature. The current required frequency for performing the EDG inspection and the requirement to perform the EDG inspection in accordance with the vendor's/manufacturer's recommendations, as applicable, are not being changed by the proposed relocation. Any future changes to the EDG inspection requirements would be controlled by the appropriate regulatory processes, e.g., 10 CFR 50.59 and 10 CFR 50.65.

Relocation of the EDG inspection requirements from the TS to licensee-controlled documents does not affect the plant design, hardware, or system operation and will not affect the ability of the EDG to perform its design function in mitigating the consequences of a postulated design basis accident. Therefore, the proposed changes do not adversely affect nuclear safety or plant operations.

G. IMPACT ON PREVIOUS SUBMITTALS We have reviewed the proposed TS changes for potential impact upon previous TS change requests currently under NRC review. No impacts have been identified.

H. SCHEDULE REQUIREMENTS We request that the NRC review and approve the proposed TS changes by April, 2003.

A-5

Attachment B-1 License Amendment Request Marked-up Technical Specifications Pages for Proposed Changes Limerick Generating Station Units 1 and 2 Docket Nos. 50-352 and 50-353 Unit 1 TS Page 3/4 8-4 Unit 2 TS Page 3/4 8-4

License Amendment Request Attachment B-1 Docket Nos. 50-352, 353 ELECTRICAL POWERSYSTEMS SURVEILLANCE REOIIIREMENTS (Continued)

b. By removing accumulated water:

1) From the day tank at least once per 31 days and after each occa-sion when the diesel is operated for greater than I hour, and

2) From the storage tank at least once per 31 days.

c. By sampling new fuel oil in accordance with ASTM04057-81 prior to addition to the storage tanks and:

1) By verifying in accordance with the tests specified in ASTM 0975-81 prior to addition to the storage tanks that the sample has:

a) An API Gravity of within 0.3 degrees at 60'F or a specific gravity of within 0.0016 at 60/60'F. when compared to the supplier's certificate or an absolute specific gravity at 60/60°F of greater than or equal to 0.83 but less than or equal to 0.89 or an API gravity at 60°F of greater than or equal to 27 degrees but less than or equal to 39 degrees.

b) A kinematic viscosity at 40°C of greater than or equal to 1.9 centistokes, but less than or equal to 4.1 centistokes. if gravity was not determined by comparison with the supplier's certification.

c) A flash point equal to or greater than 125°F, and d) A clear and bright appearance with proper color when tested in accordance with ASTM D4176-82.

2) By verifying within 31 days of obtaining the sample that the other properties specified in Table 1 of ASTM0975-81 are met when tested in accordance with ASTMD975-81 except that the analysis for sulfur may be performed in accordance with ASTM01552-79 or ASTM 02622-82.

d. At least once every 31 days by obtaining a sample of fuel oil from the storage tanks in accordance with ASTMB2276-78, and verifying that total particulate contamination is less than 10 mg/liter when checked in accordance with ASTH D2276-78, Method A, except that the filters specified in ASTH D2276-78.

Sections 5.1.6 and 5.1.7, may have a nominal pore size of up to three (3) microns.

e. At the following frequency by: Replace With "Deleted"

1. C ry 24 nth subjec ng the ese to inspec/on in 'cordan (ith p cedur s prep'ed in co junction th the itrbankMorse ners Gr p reco.,endat'ons and ts manu cturer's ecoemmen tions f this ass of/tandbyl

2. Every 24 months verify each diesel generator's capability to reject a load of greater than or equal to that of its single largest post-accident load while maintaining voltage at 4285 +/- 420 volts and frequency at 60 +/- 1.2 hz and after steady state conditions are reached, voltage is maintained at 4280 +/- 120 volts.

LIMERICK - UNIT 1 3/4 8-4 Amendment No. -, 14-0k, 1-L1, 136

License Amendment Request Attachment B-1 Docket Nos. 50-352, 353 ELECTRICAL POWER SYSTEMS SURVEILLANCE REOUIREMENTS (CQntinued)

b. By removing accumulated water:

1) From the day tank at least once per 31 days and after each occa-sion when the diesel is operated for greater than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and

2) From the storage tank at least once per 31 days.

c. By sampling new fuel oil in accordance with ASTM 04057-81 prior to addition to the storage tanks and:

1) By verifying in accordance with the tests specified in ASTM D975-81 prior to addition to the storage tanks that the sample has:

a) An API Gravity of within 0.3 degrees at 60'F or a specific gravity of within 0.0016 at 60/60'F, when compared to the supplier's certificate or an absolute specific gravity at 60/60°F of greater than or equal to 0.83 but less than or equal to 0.89 or an API gravity at 60°F of greater than or equal to 27 degrees but less than or equal to 39 degrees.

b) A kinematic viscosity at 40°C of greater than or equal to 1.9 centistokes, but less than or equal to 4.1 centistokes, if gravity was not determined by comparison with the supplier's certification.

c) A flash point equal to or greater than 125°F, and d) A clear and bright appearance with proper color when tested in accordance with ASTM D4176-82.

2) By verifying within 31 days of obtaining the sample that the other properties specified in Table 1 of ASTM D975-81 are met when tested in accordance with ASTM D975-81 except that the analysis for sulfur may be performed in accordance with ASTM D1552-79 or ASIM D2622-82.

d. At least once every 31 days by obtaining a sample of fuel oil from the storage tanks in accordance with ASTM D2276-78, and verifying that total particulate contamination is less than 10 mg/liter when checked in accordance with ASTM D2276-78, Method A, except that the filters specified in ASTM D2276-78, Sections 5.1.6 and 5.1.7, may have a nominal pore size of up to three (3) microns.

e. At the following frequency by: l Replace with "Deleted"

1) Ev ry 24,Konths bjectin thed* sel to ag inspecti in acco ance wi 7ocedu1s prep red in njunc on with 9fe Fairba s Morse Qners Gr p recompndatio and i manuf cturer's mecomienda ons for is clas of I st an y s e rv ce . """"

2) Every 24 months verify each diesel generator's capability to reject a load of greater than or equal to that of its single largest post-accident load while maintaining voltage at 4285 +/- 420 volts and frequency at 60 +/- 1.2 hz and after steady state conditions are reached, voltage is maintained at 4280

+/- 120 volts.

LIMERICK - UNIT 2 3/4 8-4 Amendment No. 34, 6-5, 89, W3, 101

Attachment B-2 License Amendment Request Marked-up Technical Specifications Pages for Proposed Changes Oyster Creek Generating Station Docket No. 50-219 TS Pages 4.7-1 4.7-4

License Amendment Request Attachment B-2 Docket No. 50-219 4.7 AUXILIARY ELECTRICAL POWER Applicability: Applies to surveillance requirements of the auxiliary electrical supply.

Objective: To verify the availability of the auxiliary electrical supply.

Specification:

A. Diesel Generator

1. Each diesel generator shall be started and loaded to not less than 80% rated load every two weeks.

2. The two diesel generators shall be automatically actuated and functionally tested during each refueling outage. This shall include testing of the diesel generator load sequence timers listed in Table 3.1.1.

3. Eac_ dieseJene 4or sh- be gen a TCroug ins tion/ireastoceer

, 2 month / / / I/ / / I Replace with "Deleted"

4. The diesel generators' fuel supply shall be checked following the above tests.

5. The diesel generators' starting batteries shall be tested and monitored per Specification 4.7.B.

B. Station Batteries and Diesel Generator Starting Batteries Weekly surveillance will be performed to verify the following:

a. The active metallic surface of the plates shall be fully covered with electrolyte in all batteries.

b. The designated pilot cell voltage is greater than or equal to 2.09 volts for Station Battery B and 2.0 volts for Station Battery C while the respective battery is on a float charge.

c. The overall battery voltage is greater than or equal to 125.4 volts for Station Battery B and 120 volts for Station Battery C while the respective battery is on a float charge. (Diesel battery; 112 volts).

d- The pilot cell specific gravity, corrected to 77°F, is greater than or equal to 1.190.

4.7-1 Amendment No.: 4-4,1-g 9, 9 227 OYSTER CREEK

License Amendment Request Attachment B-2 Docket No. 50-219 for failures and Basis: The biweekly tests of the diesel generators are primarily to check the deterioration in the system since last use. The manufacturer has recommended based on experience with many of their engines. One factor two week test interval, engine starts in determining this test interval (besides checking whether or not the runs) is that the lubricating oil should be circulated through the engine and at least 80% of approximately every two weeks. The diesels should be loaded to one hour).

rated load until engine and generator temperatures have stabilized (about prevent soot formation in the cylinders and injection The minimum 80% load will that there is no nozzles. Operation up to an equilibrium temperature ensures The tests also provide an engine and generator operating over-heat problem.

to identify and history to be compared with subsequent engine-generator test data in a system correct any mechanical or electrical deficiency before it can result failure.

procedures that The test during refueling outages is more comprehensive, including These include automatic actuation and are most effectively conducted at that time.

capability tests, to verify that the generators can start and assume load in functional timers which less than 20 seconds and testing of the diesel generator load sequence LOCA provide protection from a possible diesel generator overload during ags6"1 9 e W conditions. M a8" with regard to the The manufacturer's instructions for battery care and maintenance the equalizing charge, and the addition of water will be followed.

floating charge.

Station In addition, written records will be maintained of the battery performance.

will deteriorate with time, but precipitous failure is unlikely. The station batteries and testing practices surveillance procedures follow the recommended maintenance experience, the ability to of IEEE STD. 450 which have demonstrated, through tendencies long before such provide positive indications of cell deterioration tendencies cause cell irregularity or improper cell performance.

the capability of the The battery service test is a special capacity test to demonstrate The Oyster Creek design duty battery to meet the system design requirements.

loads are determined by a LOCA subsequent to a loss of AC power. The cycle to check it against the battery performance test is a capacity test on the battery when the battery has manufacturer's specified capacity and is used to determine arrived at the end of its life.

testing once per five IEEE Standard 450-1975 recommends battery performance 308-1974 recommends battery performance testing once per years. IEEE Standard test Specifications require a performance three years. The Oyster Creek Technical Both IEEE Standards recommend decreasing the surveillance once per two years.

85% of rated.

interval to annually when battery capacity falls below two weeks to perform the 80%

The diesel generator batteries are challenged every battery service test. The load test. This effectively performs an uninstrnmented combined with the annual battery service test, provides biweekly diesel start, when characteristics. This test data an extensive amount of data on battery performance the battery performance test interval from biennial to negates the need to lower annually.

4.7-4 AMIENDMvENT NO: 14. !8,19 27 OYSTER CREEK

Attachment B-3 License Amendment Request Marked-up Technical Specifications Pages for Proposed Changes Three Mile Island, Unit 1 Docket No. 50-289 TS Page 4-46

License Amendment Request Auacnmem D-O Docket No. 50-289 4.6 EMERGENCY POWER SYSTEM PERIODIC TESTS Applicability: Applies to periodic testing and surveillance requirement of the emergency power system.

Obiective: To verify that the emergency power system will respond promptly and properly when required.

Specification:

The following tests and surveillance shall be performed as stated:

4.6.1 Diesel Generators

a. Manually-initiate start of the diesel generator, followed by manual synchronization with other power sources and asm6nof-load by the diel enerator u~p to the name-plate ringI(3000k w). This test.wilbe* onducted every monon each desel generator.

NornaI plant opration will not be effecit o dr

b. Automatically start and loading the emergency diesel generator in accordance with Specification 4.5.1.l.b/k including the following This test will be conducted every refueling interval on each diesel generator.

(1) Verif* that the diesel generator starts from ambient condition upon receipt of the ES signal and is ready to load in: 10 seconds.

(2) Verify that the diesel block loads upon simulated loss of offsite power in

<: 30 seconds.

(3) The diesel operates -with the permanently connected and auto connected load fbr

> 5 minutes.

(4) The diesel engine does not trip when the generator breaker is opened while carrying emergency loads.

(5) The diesel generator block loads and operates for> 5 minutes upon reclosure of the diesel generator breaker.

C, die~sedg or be nan in on atI e'very2 Manthl(with25%

la] l~w e /ce. erod in acrdance wi pred/ pre"r/ i cotntmwt/f;*

Z*e man atren*r rthisecssofstniyev.

4.6.2 Station Batteries \ Replace with "Deleted"

a. The voltage, specific gravity; and liquid level of each cell will be measured and recorded:

(1) every 92 days (2) once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a battery discharge < 105 V (3) once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a battery overcharge > 150 V (4) If any cell parameters are not met, measure and record the parameters on each connected cell every 7 days thereafter until all battery parameters are met.

b. The voltage and specific gravity of a pilot cell will be measured and recorded weekly. If any pilot cell parameters are not met, perfbrm surveillance 4.6.2-a on each connected cell within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and every 7 days thereafter until all battery parameters are met

c. Each time data is recorded, new data shall be compared with old to detect signs of abuse or deterioration.

4-46 Amendment No. 70,449, 4-57, 200, 232 TMI Unit I

Attachment C License Amendment Request Docket Nos. 50-219, 50-289, 50-352, and 50-353 INFORMATION SUPPORTING A FINDING OF NO SIGNIFICANT HAZARDS CONSIDERATION

License Amendment Request Docket Nos. 50-219, 289, 352, 353 Attachment C INFORMATION SUPPORTING A FINDING OF NO SIGNIFICANT HAZARDS CONSIDERATION According to 10 CFR 50.92, "Issuance of Amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

Involve a significant increase in the probability or consequences of an accident previously evaluated; or Create the possibility of a new or different kind of accident from any accident previously evaluated; or Involve a significant reduction in a margin of safety.

In support of this determination, Exelon and AmerGen have prepared an evaluation of each of the three criteria set forth in 10 CFR 50.92 regarding the proposed license amendment.

Overview In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (i.e., Exelon) and AmerGen Energy Company, LLC (i.e., AmerGen) are requesting changes to Technical Specifications (TS), Appendix A of Facility Operating License Nos. NPF-39, NPF-85, DPR-16, and DPR-50 for Limerick Generating Station (LGS), Units 1 and 2, Oyster Creek Generating Station (OCGS), and Three Mile Island, Unit 1, respectively.

The proposed changes will delete the current Technical Specifications (TS) requirements for Emergency Diesel Generator (EDG) maintenance inspections and relocate the requirements to licensee-controlled documents, i.e., the Updated Final Safety Analysis Report or Technical Requirements Manual, as appropriate, either of which are controlled in accordance with the requirements of 10 CFR 50.59.

The proposed amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed TS changes are administrative changes to relocate the current EDG maintenance inspection requirements.

The EDGs are designed to provide a reliable alternative source of AC electrical power in the event of an accident coincident with the loss of offsite power. The failure of an EDG itself is not considered as an accident evaluated in the UFSAR. The proposed administrative changes to relocate the maintenance inspection requirements do not affect the current accident initiators or precursors that could lead to a previously evaluated accident.

The failure of a single EDG to respond when required to mitigate the consequences of an accident has already been considered as a subsequent single failure in the current plant safety C-1

License Amendment Request Docket Nos. 50-219, 289, 352, 353 Attachment C INFORMATION SUPPORTING A FINDING OF NO SIGNIFICANT HAZARDS CONSIDERATION analyses. The proposed administrative changes to relocate the maintenance inspection requirements do not alter the EDG design features, operation, or accident analysis assumptions which could affect the ability of the EDGs to mitigate the consequences of a previously evaluated accident. Current TS testing requirements for the EDGs, e.g., starting, timing, loading, and sequencing, will continue to ensure reliable EDG operation and are not being changed in this request.

Since only the relocation of EDG maintenance inspection requirements is involved, the proposed changes will not increase the likelihood of the malfunction of another system, structure or component which has been assumed as an accident initiator or credited in the mitigation of an accident.

Based on the above discussion, the proposed TS changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed amendments do not create the possibility of a new or different kind of accident from any accident previously evaluated.

The EDGs are designed to provide a reliable alternative source of AC electrical power in the event of an accident coincident with the loss of offsite power. The proposed TS changes are administrative changes to relocate the EDG maintenance inspection requirements.

No change in the ability to perform the design function of the EDGs is involved. No change in the operation of the EDGs is required. Instrumentation setpoints, starting, sequencing, and loading functions associated with the EDGs are not affected by the proposed changes. No modifications to the EDGs are required to implement the proposed TS changes. Therefore, no new failure mechanism, malfunction, or accident initiator is considered credible.

Additionally, the proposed TS changes do not affect other plant design, hardware, system operation, or procedures. Therefore, based on the above discussion, the proposed TS changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendments do not involve a significant reduction in a margin of safety.

The proposed TS changes are administrative changes to relocate the current EDG maintenance requirements.

The consideration of safety margins for this amendment included a review of the acceptance criteria for emergency core cooling systems for light water nuclear power reactors in 10 CFR 50.46, and ECCS evaluation models in Appendix K to 10 CFR 50. The proposed amendments do not involve a relaxation of the criteria used to establish safety limits, a relaxation of the bases for the limiting safety system settings, nor a relaxation of the bases for the limiting conditions for operation.

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License Amendment Request Docket Nos. 50-219, 289, 352, 353 Attachment C INFORMATION SUPPORTING A FINDING OF NO SIGNIFICANT HAZARDS CONSIDERATION Controlling values for the EDGs are included in current TS testing requirements, e.g., EDG starting, timing, loading, and sequencing. The proposed amendment will not modify these requirements or the accident analysis assumptions regarding the performance of the EDGs which could potentially challenge safety margins established to ensure fuel cladding integrity, as well as reactor coolant and containment system integrity.

The safety analyses of the EDGs' ability to mitigate accidents do not require revision in order to implement the proposed amendment. Modification of the existing margins is not required.

Based on the above discussion, the proposed TS changes do not involve a significant reduction in a margin of safety.

Conclusion Based upon the above evaluation, Exelon and AmerGen have concluded that the three criteria of 10 CFR 50.92(c) are satisfied and that the proposed changes to the TS involve no significant hazards consideration.

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Attachment D License Amendment Request Docket Nos. 50-219, 50-289, 50-352, and 50-353 INFORMATION SUPPORTING AN ENVIRONMENTAL ASSESSMENT

License Amendment Request Docket Nos. 50-219, 289, 352, 353 Attachment D INFORMATION SUPPORTING AN ENVIRONMENTAL ASSESSMENT In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (i.e., Exelon) and AmerGen Energy Company, LLC (i.e., AmerGen) are requesting changes to Technical Specifications, Appendix A of Facility Operating License Nos. NPF-39, NPF-85, DPR-16, and DPR-50 for Limerick Generating Station, Units 1 and 2, Oyster Creek Generating Station, and Three Mile Island, Unit 1, respectively.

The proposed changes will relocate Technical Specification requirements regarding the maintenance inspections of Emergency Diesel Generators to licensee-controlled documents, i.e., the Updated Final Safety Analysis Report or Technical Requirements Manual, as appropriate, either of which are controlled in accordance with the requirements of 10 CFR 50.59. EDG maintenance is currently performed under the Exelon and AmerGen 10 CFR 50.65 Maintenance Rule Programs. The relocation of the maintenance inspection requirements for EDGs to licensee-controlled documents is administrative in nature and was generically approved by the NRC in NUREG-1 430, "Standard Technical Specifications, Babcock and Wilcox Plants," and NUREG-1 433, "Standard Technical Specifications, General Electric Plants (BWR/4)."

Exelon and AmerGen have evaluated the proposed TS change request consistent with the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21, "Criteria for and identification of licensing and regulatory actions requiring environmental assessments." Exelon and AmerGen have determined that this proposed TS change request meets the criteria for a categorical exclusion set forth in paragraph (c)(9) of 10 CFR 51.22.

This determination is based on the fact that these changes are being proposed as amendments to licenses issued pursuant to 10 CFR 50, which change an inspection or a surveillance requirement, and that (i) the amendment involves no significant hazards consideration, (ii)there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii) there is no significant increase in individual or cumulative occupational radiation exposure.

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

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