Text

License Amendment Request 01-01167 Re Revision to Technical Specifications Regarding a Missed Surveillance Using the Consolidated Line Item Improvement Process
	ML021570175
Person / Time
Site:	Limerick
Issue date:	05/14/2002
From:	Gallagher M; Exelon Nuclear
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML021570175 (49)
	v • d • e

Exelon Nuclear www.exeloncorp.com NEucleeaI 200 Exelon Way Kennett Square, PA 19348 10OFR50.90 May 14, 2002 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. NPF 50-352 and NPF 50-353

Subject:

License Amendment Request 01-01167 Revision to Technical Specifications Regarding a Missed Surveillance Using The Consolidated Line Item Improvement Process

Reference:

Technical Specifications Task Force (TSTF) Traveler-358, "Missed Surveillance Requirements," Revision 5, as modified by Federal Register Notice 66FR32400, dated June 14, 2001 and in response to public comments Pursuant to 1 OCFR50.90, Exelon Generation Company (EGC), LLC proposes changes to Appendix A, Technical Specifications (TS), of the Limerick Generating Station (LGS) Units 1 & 2 Facility Operating Licenses. The proposed changes would modify TS requirements for a missed surveillance through revision of Specifications 4.0.1 and 4.0.3.

In addition, in conjunction with the proposed changes, TS requirements are added for a TS Bases Control Program consistent with the TS Bases Control Program described in NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4," Rev. 2. The proposed changes are consistent with the NRC approved industry Technical Specification Task Force (TSTF) change TSTF-358, Revision 5 (Reference above).

The proposed changes are being submitted as a Consolidated Line Item Improvement Process (CLIIP) amendment. The availability of this TS improvement was noticed in the Federal Register 66FR49714, dated September 28, 2001.

Additionally, two administrative changes are proposed. The first deletes the position of "Sr.

Manager - Operations" and replaces it using an overall statement referencing the ANSI Standard for "Operations Manager". This is the recommended practice as stated in NUREG 1433 Rev. 2. The second administrative change revises the LGS TS requirement for PORC member composition replacing "Experience Assessment" with "Regulatory Assurance" to reflect Exelon organizational changes.

The proposed changes have been reviewed by the Plant Operations Review Committee and approved by the Nuclear Safety Review Board. This information is being submitted under unsworn declaration.

Revision to Technical Specifications Regarding a Missed Surveillance Using The Consolidated Line Item Improvement Process May 14, 2002 Page 2 We are notifying the State of Pennsylvania of this application for changes to the TS and Operating Licenses by transmitting a copy of this letter and its attachments to the designated state officials.

Exelon requests approval of the proposed amendment by November 14, 2002.

Once approved, this amendment shall be implemented within 60 days of issuance. This proposed amendment request is subdivided as follows.

1. Attachment 1 provides a description of the proposed changes, the requested confirmation of applicability of the model safety evaluation (SE) and no significant hazards consideration (NSHC) determination, and plant-specific verifications.

2. Attachment 2 includes the marked-up TS pages.

3. Attachment 3 provides the camera-ready TS pages.

4. Attachment 4 provides a summary of the licensing commitments made in this submittal.

5. Attachment 5 provides the existing TS Bases pages, marked up to show the proposed changes. The TS Bases changes are provided for information only.

If you have any questions or require additional information, please contact me at (610) 765 5664.

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

Respectfully,

Enclosures:

Executed on 3__/_f__'_L : : : : : :

Michael P. Gallagher Director, Licensing and Regulatory Affairs Mid-Atlantic Regional Operating Group Description and Assessment Marked-Up TS Pages Camera-ready TS Pages List of Commitments Marked-up TS Bases pages (Information only)

Camera-ready TS Bases pages cc:

H. J. Miller, Administrator, Region I, USNRC A. L. Burritt, USNRC Senior Resident Inspector, LGS C. Gratton, Senior Project Manager, USNRC R. R. Janati, Commonwealth of Pennsylvania

A1TACHMENT 1 DESCRIPTION AND ASSESSMENT LIMERICK GENERATING STATION UNITS 1 and 2 DOCKET NOS. 50-352 50-353 LICENSE NOS. NPF-39 NPF-85 LICENSE AMENDMENT REQUEST 01-01167 "Revision to Technical Specifications Regarding a Missed Surveillance Using The Consolidated Line Item Improvement Process"

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT

1.0 INTRODUCTION

In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company (EGC), LLC, proposes changes to the Limerick Generating Station Units 1 & 2 (LGS) Technical Specifications (TS), Facility Operating License Nos. NPF-39 and NPF-85.

The proposed changes would modify the TS requirements for a missed surveillance through revision of LGS TS 4.0.1 and 4.0.3. In addition, in conjunction with the proposed changes, TS requirements are added for a TS Bases Control Program consistent with the TS Bases Control Program described in NUREG-1433 (Reference 4).

Additionally, two administrative changes are proposed. The first deletes the position of "Sr. Manager - Operations" and replaces it using an overall statement referencing the ANSI Standard for "Operations Manager". This is the recommended practice as stated in NUREG-1 433. The second administrative change revises the LGS TS requirement for PORC member composition due to Exelon organizational changes.

2.0 DESCRIPTION

This license amendment request (LAR) revises LGS TS 4.0.1 and 4.0.3 to be consistent with NUREG-1433 (Reference 4) and with the NRC approved industry Technical Specification Task Force (TSTF) traveler TSTF-358, Revision 5 (Reference 1) as modified by Federal Register Notice 66FR32400, dated June 14, 2001 (Reference 2) and in response to public comments. Since LGS is a non-Improved Standard Technical Specification plant, additional changes are required to LGS TS 4.0.1 and 4.0.3 so that TSTF-358 can be utilized via the Consolidated Line Item Improvement Process (CLIIP).

The TS Bases for LGS TS 4.0.1 and 4.0.3 have also been revised in accordance with NUREG-1433.

In addition, this LAR adds a TS Bases Control Program to the LGS TS. This program is identical to the TS Bases control program described in NUREG-1433.

The proposed changes are being submitted under the CLIIP as noticed in the Federal Register, 66FR49714, dated September 28, 2001 (Reference 3).

This LAR proposes two administrative changes as well. The first change, to LGS TS 6.2.2.g, deletes the position title of "Sr. Manager - Operations" and replaces it using an overall statement referencing the ANSI Standard for "Operations Manager". This is the recommended practice as stated in NUREG-1433. The second administrative change revises the LGS TS requirement for PORC member composition due to EGC organizational changes. The "Experience Assessment" group has been renamed "Regulatory Assurance", which affects LGS TS 6.5.1.2. Please note that these administrative changes will not be discussed in the "Assessment" section below, but will be discussed in the "No Significant Hazards Consideration" and "Environmental Evaluation".

Page 1 of 6

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT

3.0 ASSESSMENT

3.1 Applicability of Published Safety Evaluation EGC has reviewed the safety evaluation dated June 14, 2001 (Reference 2), as referenced in the notice of availability of this CLIIP, dated September 28, 2001 (Reference 3). This review included a review of the NRC staff evaluation, as well as the supporting information provided to support TSTF-358.

EGC has concluded that the justification presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to LGS, and hereby incorporates by reference the safety evaluation presented in the CLIIP and TSTF-358, Rev. 5 into this submittal. Since LGS does not currently have a TS Bases Control Program, EGC also incorporates by reference the Optional Section of the safety evaluation applicable to licensees adopting a Bases Control Program.

It should be noted that while the published Safety Evaluation refers to Surveillance Requirements (SR) 3.0.1 and 3.0.3 and the LGS TS contain related Specifications 4.0.1 and 4.0.3, the justification is still applicable to the LGS TS as modified by this license amendment request.

3.2 Optional Changes and Variations There are some plant-specific changes proposed that vary from the subject CLIIP item, whose availability was noticed in the Federal Register, 66FR49714, dated September 28, 2001 (Reference 3).

LGS Technical Specifications (TS) 4.0.1 and 4.0.3 have been re-written to match SRs 3.0.1 and 3.0.3, respectively, from NUREG-1433 (Reference 4).

LGS TS 4.0.1 NUREG-1433 SR 3.0.1 is constructed to more completely represent the relationship between Surveillance Requirements and meeting the requirements of the LCO. Using NUREG-1433 SR 3.0.1 as the basis, the concepts within the existing LGS TS 4.0.3 are combined with the existing LGS TS 4.0.1, into the proposed LGS TS 4.0.1.

LGS TS 4.0.3 Both LGS TS 4.0.3 and NUREG-1433 SR 3.0.3 allow that, at the time it is discovered that the Surveillance has not been performed, the requirement to declare the equipment inoperable (LCO not met) may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This is based on NRC Generic Letter 87-09, which states, "It is overly conservative to assume that systems or components are inoperable when a surveillance has not been performed. The opposite is in fact the case, the vast majority of surveillances demonstrate that systems or components in fact are operable. When a Surveillance is missed, it is primarily a question of operability that has not been verified by the performance of the required surveillance."

Based on consideration of plant conditions, adequate planning, availability of personnel, the time required to perform the Surveillance and the safety significance of the delay in completing the Surveillance, the NRC concluded in Generic Letter 87-09 that 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is an acceptable time limit for completing a missed Surveillance when the allowable outage Page 2 of 6

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT times of the ACTIONS are less than the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limit or a shutdown is required to comply with ACTIONS.

However, following the argument that led to the development of NUREG-1 433 SR 3.0.3, it stands to reason that since 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months has been determined to be an acceptable time limit for completing the Surveillance, this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months deferral should apply to all systems or components, regardless of whether or not their ACTIONS completion time is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or less. This is primarily because shorter completion times are generally provided for more safety significant ACTIONS. Therefore, if a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months delay can be safely applied to an ACTION with a short (e.g., 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ) completion time, there should be less of a safety impact when a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months delay is applied to an ACTION with a long (e.g., 7 day) completion time. Furthermore, consistent application of the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months delay regardless of completion time is critical to eliminating potential confusion and misapplication.

Therefore, SR 3.0.3 (Reference 4), and the proposed LGS TS 4.0.3 based on it, have eliminated the restriction that the extension only applies to outage times less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The second and third paragraphs of LGS TS 4.0.3 are added to clearly state the actions to take if the Surveillance is not performed within the delay period or the Surveillance fails when performed. This clarification helps avoid confusion as to when to enter the ACTIONS in various situations.

The associated LGS TS Bases sections, 4.0.1 and 4.0.3, are revised per NUREG-1 433 and the subject CLIIP. They are included, for information only, as Attachment 5 to this license amendment request.

4.0 REGULATORY ANALYSIS

4.1 No Significant Hazards Determination CHANGES TO LGS TS 4.0.1 & 4.0.3 AND ADDITION OF TS BASES CONTROL PROGRAM EGC has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. EGC has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to LGS and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

CHANGES TO LGS TS SECTION 6 In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company (EGC), LLC is requesting changes to Appendix A, Technical Specifications (TS) of Facility Operating License Nos. NPF-39 and NPF-85, for Limerick Generating Station (LGS), Units 1 and 2.

The proposed changes will address the following issues:

TS Section 6.2.2, "Unit Staff," Specification 6.2.2.g. is being revised to replace the position title of Sr. Manager - Operations by use of an overall statement referencing the ANSI Standard for "Operations Manager". This is the recommended practice as stated in NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4,"

Revision 2, dated June 2001.

Page 3 of 6

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT TS 6.5.1.2 "Composition" is being revised to replace "Experience Assessment' with "Regulatory Assurance" as the required area of experience for the collective Plant Onsite Review Committee (PORC) membership.

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

The proposed TS and licensing basis changes are administrative changes to eliminate obsolete position and work group titles and incorporate the equivalent titles in use by EGC at other fleet nuclear facilities.

These changes do not involve any physical change to structures, systems, or components (SSCs) and does not alter the method of operation or control of SSCs. The current assumptions in the safety analysis regarding accident initiators and mitigation of accidents are unaffected by these administrative changes. No additional failure modes or mechanisms are being introduced and the likelihood of previously analyzed failures remains unchanged.

The integrity of fission product barriers, plant configuration, and operating procedures will not be affected by these changes. Therefore, the consequences of previously analyzed accidents will not increase because of these changes.

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 amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed TS and licensing basis changes are administrative changes to eliminate obsolete position and work group titles and incorporate the equivalent titles in use by EGC at other fleet nuclear facilities.

The current accident analysis will remain valid following these administrative changes to TS.

The changes will not alter the administrative functions that are currently in use. The qualification requirements for the individuals performing the affected TS administrative functions will remain unchanged.

The proposed TS changes do not affect 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 amendment does not involve a significant reduction in a margin of safety.

The proposed TS and licensing basis changes are administrative changes to revise current position titles to reflect equivalent position titles in use by EGC at other fleet nuclear facilities.

The revision of the collective experience of the PORC membership to include Regulatory Assurance experience is equivalent to the current requirement for Experience Assessment Page 4 of 6

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT experience. The functions of the Regulatory Assurance group remain essentially unchanged due to merger initiatives. The Regulatory Assurance group is the site process owner for the Corrective Action Process (CAP), the Self Assessment Process, the PORC Process, the Commitment Tracking Process, the Operating Experience Process, support of NRC inspections and issue closure. Therefore, there is no reduction in PORC member qualification requirements due to this change.

The requirement for the "Operations Manager" to hold a Senior Reactor Operator license is equivalent to the requirement for the Sr. Manager - Operations or an Operations Manager to hold a Senior Reactor Operator license.

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

Conclusion Based upon the evaluation above, we 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.

4.2 Verification and Commitments for Changes to LGS TS 4.0.1 & 4.0.3 As discussed in the notice of availability published in the Federal Register on September 28, 2001 for this TS improvement, plant-specific verifications were performed.

EGC has established TS Bases for LGS TS 4.0.3 which state that use of the delay period established by Specification 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals, but only for the performance of missed surveillances.

The LAR also includes changes to the Bases for LGS TS 4.0.3 that provide details on how to implement the new requirements. The Bases changes provide guidance for surveillance frequencies that are not based on time intervals but are based on specified unit conditions, operating situations, or requirements of regulations. In addition, the Bases changes state that EGC is expected to perform a missed surveillance test at the first reasonable opportunity, taking into account appropriate considerations, such as the impact on plant risk and accident analysis assumptions, consideration of unit conditions, planning, availability of personnel, and the time required to perform the surveillance. The Bases also state that the risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants," and that the missed surveillance should be treated as an emergent condition, as discussed in Regulatory Guide 1.182. In addition, the Bases will state that the degree of depth and rigor of the evaluation should be commensurate with the importance of the component and that missed surveillances for important components should be analyzed quantitatively. The Bases will also state that the results of the risk evaluation determine the safest course of action. In addition, the Bases will state that all missed surveillances will be placed in the station's Corrective Action Program.

Finally, this LAR proposes a TS change that incorporates a TS Bases Control Program consistent with Section 5.5 of NUREG-1433, Rev. 2.

Page 5 of 6

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT 5.0 ENVIRONMENTAL EVALUATION CHANGES TO LGS TS 4.0.1 & 4.0.3 EGC has reviewed the environmental evaluation included in the model safety evaluation dated June 14, 2001, as part of the CLIIP (Reference 2). EGC has concluded that the staff's findings presented in that evaluation are applicable to LGS and the environmental evaluation is hereby incorporated by reference for this application.

CHANGES TO LGS TS SECTION 6 An environmental assessment is not required for the proposed changes since the proposed changes conform to the criteria for "actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9). The proposed changes will have no impact on the environment. The proposed changes do not involve a significant hazards consideration as discussed in the preceding section. The proposed changes do not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. In addition, the proposed changes do not involve a significant increase in individual or cumulative occupational radiation exposure.

6.0 REFERENCES

1 Industry/Technical Specifications Task Force Standard Technical Specification Change Traveler-358, "Missed Surveillance Requirements," Revision 5, as modified by Federal Register Notice 66FR32400, dated June 14, 2001 and in response to public comments 2

Federal Register, Volume 66, Number 115, Pages 32400-32407, "Notice of Opportunity To Comment on Model Safety Evaluation on Technical Specification Improvement To Modify Requirements Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process," dated June 14, 2001 3

Federal Register, Volume 66, Number 189, Pages 49714-49717, "Notice of Availability of Model Application Concerning Technical Specification Improvement To Modify Requirements Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process," dated September 28, 2001

4.

NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4,"

Revision 2, dated June 2001.

Page 6 of 6

ATTACHMENT 2 MARKED-UP TECHNICAL SPECIFICATIONS PAGES LIMERICK GENERATING STATION UNITS 1 and 2 DOCKET NOS. 50-352 50-353 LICENSE NOS. NPF-39 NPF-85 LICENSE AMENDMENT REQUEST 01-01167 "Revision to Technical Specifications Regarding a Missed Surveillance Using The Consolidated Line Item Improvement Process" REVISED TS PAGES UNIT 1 3/4 0-2 6-3 6-7 6-14c UNIT 2 3/4 0-2 6-3 6-7 6-14c

Inserts for LGS License Amendment Request to Modify Technical Specification Requirements Regarding Missed Surveillances Using the CLIIP Insert 1:

Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance within the specified Surveillance time interval and allowed extension per Specification 4.0.2, shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

Insert 2:

If it is discovered that a Surveillance was not performed within its specified Surveillance time interval and allowed extension per Specification 4.0.2, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Surveillance time interval, whichever is greater.

This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

Insert 3:

h.

Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b.

Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

A change in the TS incorporated in the license; or A change to the UFSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c.

The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the UFSAR.

Insert 3 continued

d.

Proposed changes that meet the criteria of b. above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

APPLICABILITY SURVEILLANCE REOUIREMENTS 4.0.1 urv/1l.lance Requi*r ents shall be *et during the OPERTINA FCODITION,$or othel o

ions specifi for individualA JKfig Cond os k~or Opepetion unless Ferwise stateýi~n an individual,-Surveillnce Requirement 4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance time interval with a maximum allowable extension not to exceed 25%

of the surveillance interval.

pf rm lue th perform a Surveillance Requirement within the allo ed Opirits ofThe AtiON riaso teA~Oequirements are lessthan oursaSurv lanc n opermith coleo othsuvyflne whenh h

thinwal Coutandie tj0n o

.ISnonc l

mpits f te withO thrOeu Iireets areqless than f'o r.SrvaLi itin lCndtinc fo requirements do not hayvtobe performed on inoperable equipment.

4.0.4 Entry into an OPERATIONAL CONDITION or other specified applicable condi tion shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the applicable surveillance interval or as otherwise specified.

This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, & 3 components shall be applicable as follows:

a.

Inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50, Section 50.55a.

b.

Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications:

Amendment No.

44, 38, 125 3/4 0-2 LIMERICK -UNIT I

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

g.

Primary Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54 (o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions.

This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163 "Performance-Based Containment Leakage Test program," dated September 1995.

The peak calculated containment internal pressure for the design basis loss coolant accident, P., is 44.0 psig.

The maximum allowable primary containment leakage rate, L., at P., shall be 0.5% of primary containment air weight per day.

Leakage rate acceptance criteria are:

a.

Primary Containment leakage rate acceptance criterion is less than ot equal to 1.0 L,.

During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria ar less than or equal to 0.60 L. for the Type B and Type C tests and les than or equal to 0.75 L. for Type A tests;

b.

Air lock testing acceptance criteria are:

1) Overall airlock leakage rate is less than or equal to 0.05 L.

when tested at greater than or equal to P,.

2)

Seal leakage rate is less than or equal to 5 scf per hour when the gap between the door seals is pressurized to 10 psig.

The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.

The provisions of Specification 4.0.3 are applicable to the tests described in the Primary Containment Leakage Rate Testing Program.

rAN2 419 3

JAN 2 4 1997 Amendment No.

118 LIMERICK - UNIT I 6-14c

.-ADMI'NISTRATIVE CONTROLS UNIT STAFF (Continued)

Any deviation from the above guidelines shall be authorized by the Plant Manager or personnel designated in administrative procedures or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.

Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the Plant Manager, or the appropriate designated personnel to assure that excessive hours have not been assigned.

Routine deviation from the above guidelines is not authorized; I

V AUG 0 8 1995 Amendment No. 10,,,0,ý0,96 LIMERICK -

UNIT 1 6-3

AADMIN 7 STRATIVE CONTROLS 6.4 TRAINING 6.4.1 Training programs for the unit staff shall be maintained under the

)irection of the site training organization.

The retraining and replacement training programs for all affected positions except licensed operators shall meet or exceed the standards of ANSI/ANS 3.1-1978.

The retraining and replacement training programs for licensed operators shall comply with the requirements of 10 CFR 55, and shall include familiarization with relevant industry operational experience.

6.5 REVIEW AND AUDIT 6.5.1 PLANT OPERATIONS REVIEW COMMITTEE (PORC)

FUNCTION 6.5.1.1 The PORC shall function to advise the Plant Manager on all matters related to nuclear safety.

COMPOSITION 6.5.1.2 The Plant Operations Review Committee is composed of nine regular members from the Limerick Generating Station staff.

Members shall collectively have experience in the following areas:

Plant Operations Engineering Maintenance Instrumentation and Controls

__A__e-S Planning Radiation Safety Members shall meet the requirements of ANSI/ANS 3.1-1978, Section 4.7, for the applicable required experience and be appointed in writing by the Plant Manager.

The Chairman and alternate Chairmen of the PORC shall be drawn from the PORC members and appointed in writing by the Plant Manager.

ALTERNATES 6.5.1.3 All alternate members shall be appointed in writing by the PORC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in PORC activities at any one time.

MEETING FREQUENCY 6.5.1.4 The PORC shall meet at least once per calendar month and as convened by the PORC Chairman or his designated alternate.

6.5.1.5 The quorum of the PORC necessary for the performance of the PORC responsibility and authority provisions of these Technical Specifications shall

-isist of the Chairman or his designated alternate and four members including Iernates.

M;f4 2ii0G LIMERICK - UNIT I 6-7 Amendment No.

Gerrecti an1 Ltr 10, U, 5%, 005 139 dutd 1U/1 H9//ý5, I

APPLICABILITY SURVEILLANCE REOUIREMENTS 4.0.1 Survei lance Requir ments shall be m9t during the OERATIONAL s p c i i e 1 f* r i i n d ii d a Vm i

.t~i n g C o n d i e{

i o n s CONDITIONS 0other co d

~ons onsi-Ji id a for Opera

on unless o+erwise stated i an individual. Kurveillance R4quirement.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance time interval with a maximum allowable extension not to exceed 25% of the surveillance interval.

4.0.3 Failure to perform a Surveillance Requirement within the allowed surveillanc interv efined by Sp ification 4..0.2, shall constitute Si anofi n er f ned Sb pe*

f c t o U¶Operatio {.

The time imits of the *TION requirement are applicable #t-the perfo T~ed.

The AC I~ON requireme s may be delayed/ or up to 24 hour* to per *t the,compi ~ion of the su eillance when th 'allowable outag /time 4.0.4 Entry into an OPERATIONAL CONDITION or other specified applicable condi tion shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have.been performed within the applicable surveillance interval or as otherwise specified.

This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2,

& 3 components shall be applicable as follows:

a.

Inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler S........ and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50, Section 50.55-a.

b.

Surveillance intervals specified in Section XI of the ASMEBoiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code a n

a applicable Addenda shall be applicable as follows in these Technical Specifications:

Amendment No.

4, 89 3/4 0-2 LIMERICK

-UNIT 2

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

g.

Primary Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54 (o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions.

This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163 "Performance-Based Containment Leakage Test program," dated September 1995.

The peak calculated containment internal pressure for the design basis loss of coolant accident, P., is 44.0 psig.

The maximum allowable primary containment leakage rate, L., at P., shall be 0.5% of primary containment air weight per day..

Leakage rate acceptance criteria are:

a.

Primary Containment leakage rate acceptance criterion is less than or equal to 1.0 L..

During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are less than. or equal to 0.60 L. for the Type B and Type C tests and less than or equal to 0.75 L. for Type A tests;

b.

Air lock testing acceptance criteria are:

1) Overall airlock leakage rate is less than or equal to 0.05 L.

when tested at greater than or equal to P,.

2) Seal leakage rate is less than or equal to 5 scf per hour when the gap between the door seals is pressurized to 10 psig.

The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.

The provisions of Specification 4.0.3 are applicable to the tests described in the Primary Containment Leakage Rate Testing Program.

JAN 2 4 1997 LIMERICK - UNIT 2 6-14c Amendment No.

81

-ADMINISTRATIVE CONTROLS 6.2.2 UNIT STAFF (Continued)

3.

A break of at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months should be allowed between work periods, including shift turnover time.

4.

Except during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift.

Any deviation from the above guidelines shall be authorized by the Plant Manager or personnel designated in administrative procedures or higher levels of management, in accordance with established pro cedures and with documentation of the basis for granting the devia tion.

Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the Plant Manager, or the appropriate designated personnel to assure that excessive hours have not been assigned.

Routine deviation from the above guidelines is not authorized; and

.T ~Sr Manag

- -pration0sha defined by ANSI/ANS-3.1-1 978 section 4.2.2 or another Manager in Operations shall hold a Senior Reactor Opeator License.

6-3 Amendment No. Z,2$,41,60 LIMERICK - UNIT 2 AVG 0 8 1995

ADMINI.STRATIVE CONTROLS 6.4 TRAINING

-"'6.4.1 Training programs for the unit staff shall be maintained under the

..direction of the site training organization.

The retra.infing and replacement training programs for all affected positions except licensed operators shall meet or exceed the standards of ANS.I/ANS 3.1-1978. The -retraining. and replacement training programs fr

.licensed operators shall complywith the requirements of 10 CFR 55, and :shall i nclude" famil i arizati on with relevant industry ope-rtiona experience.

6.5 REVIEW AND AUDIT 6.5.1 PLANT OPERATIONS:RE-VIEW '-COMMITTEE (PORC)

FUNCTION 6.5.1.1 The. PORC shall function to advise the Plant Manager on all matters related to nuclear safety.

COMPOS-ITIO64 6.5.1.2 The Pl Operations Review CommitteeD is tomposed" of nfine regular members from the Limerick Generating Station staff.

Members s hall collectively have experience in the following areas:

Plant:^Operati 'ji Engineering Mainten~

anrinrlceE LC Members shall meet the requirements of ANSI/ANS3.1-1978, Section' 4.74e for the appýiicabl.e required experience and be appointe*din writing b..ythe* PIant anager.

The Chairman and alternalte Chairmen of the PQRC"shall be di-:wn from-the PORCsniembers and appointed i:n writing bythe -lant Manae.

ALTERNATES 6.5.1.3 All alternate members shall be appointed in writing by t1e PORC Chairman to serve on a temporary basis; however, no more than tw alternates shall participate as voting members in PORC activities at any one time.

MEETING FREQUENCY 6.5.1.4 The PORC shall meet at least once per calendar month and as convened by the PORC Chairman or his designated alternate.

QUORUM 6.5.1.5 The quorum of the PORC necessary for the performance of the PORC responsibility and authority provisions of these Technical Specifications shall ansist of the Chairman or his designated alternate and four members including i

-ternates.

LIMERICK - UNIT 2 6-7 Amendment No. i0, *0, 102 MARt 1 4 K53

ATTACHMENT 3 CAMERA-READY TECHNICAL SPECIFICATIONS PAGES LIMERICK GENERATING STATION UNITS 1 and 2 DOCKET NOS. 50-352 50-353 LICENSE NOS. NPF-39 NPF-85 LICENSE AMENDMENT REQUEST 01 -01167 "Revision to Technical Specifications Regarding a Missed Surveillance Using The Consolidated Line Item Improvement Process" REVISED TS PAGES UNIT 1 3/4 0-2 6-3 6-7 6-14c UNIT 2 3/4 0-2 6-3 6-7 6-14c

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation.

Failure to perform a Surveillance within the specified Surveillance time interval and allowed extension per Specification 4.0.2,shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance time interval with a maximum allowable extension not to exceed 25%

of the surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified Surveillance time interval and allowed extension per Specification 4.0.2, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Surveillance time interval, whichever is greater.

This delay period is permitted to allow performance of the Surveillance.

A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

4.0.4 Entry into an OPERATIONAL CONDITION or other specified applicable condi tion shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the applicable surveillance interval or as otherwise specified.

This provision shall not prevent passage through or to OPERATIONAL CONDITIONS as required to comply with ACTION requirements.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, & 3 components shall be applicable as follows:

a.

Inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50, Section 50.55a.

b.

Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications:

Amendment No. -4, -8, 2-5, LIMERICK -UNIT I

3/4 0-2

ADMINISTRATIVE CONTROLS UNIT STAFF (Continued)

Any deviation from the above guidelines shall be authorized by the Plant Manager or personnel designated in administrative procedures or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.

Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the Plant Manager, or the appropriate designated personnel to assure that excessive hours have not been assigned.

Routine deviation from the above guidelines is not authorized; and

g.

The individual filling the position of Operations Manager as defined by ANSI/ANS-3.1-1978 section 4.2.2 or another Manager in Operations shall hold a Senior Reactor Operator License.

Amendment No. 4-!,

3-5, 6-,

8P, -,

LIMERICK - UNIT 1 6-3

ADMINISTRATIVE CONTROLS 6.4 TRAINING 6.4.1 Training programs for the unit staff direction of the site training organization.

training programs for all affected positions or exceed the standards of ANSI/ANS 3.1-1978, training programs for licensed operators shal CFR 55, and shall include familiarization wii experience.

shall be maintained under the The retraining and replacement except licensed operators shall meet The retraining and replacement 1 comply with the requirements of 10 th relevant industry operational 6.5 REVIEW AND AUDIT 6.5.1 PLANT OPERATIONS REVIEW COMMITTEE (PORC)

FUNCTION 6.5.1.1 The PORC shall function to advise the Plant Manager on all matters related to nuclear safety.

COMPOSITION 6.5.1.2 The Plant Operations Review Committee is composed of nine regular members from the Limerick Generating Station staff.

Members shall collectively have experience in the following areas:

Plant Operations Engineering Maintenance Instrumentation and Controls Planning Radiation Safety Chemistry Regulatory Assurance Members shall meet the requirements of ANSI/ANS 3.1-1978, Section 4.7, for the applicable required experience and be appointed in writing by the Plant Manager.

The Chairman and alternate Chairmen of the PORC shall be drawn from the PORC members and appointed in writing by the Plant Manager.

ALTERNATES 6.5.1.3 All alternate members shall be appointed in writing by the PORC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in PORC activities at any one time.

MEETING FREQUENCY 6.5.1.4 The PORC shall meet at least once per calendar month and as convened by the PORC Chairman or his designated alternate.

QUORUM 6.5.1.5 The quorum of the PORC necessary for the performance of the PORC responsibility and authority provisions of these Technical Specifications shall consist of the Chairman or his designated alternate and four members including alternates.

LIMERICK -

UNIT 1 6-7 Amendment No.

4-0, -3, -55, 96, 4-3-9, Corrected by Ltr. dtd 10/17/95

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

g.

Primary Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54 (o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions.

This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163 "Performance-Based Containment Leakage Test program," dated September 1995.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 44.0 psig.

The maximum allowable primary containment leakage rate, La, at Pa, shall be 0.5% of primary containment air weight per day.

Leakage rate acceptance criteria are:

a.

Primary Containment leakage rate acceptance criterion is less than or equal to 1.0 La.

During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are less than or equal to 0.60 La for the Type B and Type C tests and less than or equal to 0.75 La for Type A tests;

b.

Air lock testing acceptance criteria are:

1)

Overall airlock leakage rate is less than or equal to 0.05 L, when tested at greater than or equal to Pa.

2)

Seal leakage rate is less than or equal to 5 scf per hour when the gap between the door seals is pressurized to 10 psig.

The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.

The provisions of Specification 4.0.3 are applicable to the tests described in the Primary Containment Leakage Rate Testing Program.

h.

Technical Specifications (TS)

Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a.

Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b.

Licensees may make changes to Bases without prior NRC approval provided the changes do not involve either of the following:

A change in the TS incorporated in the license; or A change to the UFSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c.

The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the UFSAR.

d.

Proposed changes that meet the criteria of b.

above shall be reviewed and approved by the NRC prior to implementation.

Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

LIMERICK - UNIT 1 6-14c Amendment No.

4-18.

I

APPLICABILITY SURVEILLANCE REOUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation.

Failure to perform a Surveillance within the specified Surveillance time interval and allowed extension per Specification 4.0.2, shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3.