ML030030022

Issuance of License Amendments 163 & 125 Pressure/Temperature Curves

ML030030022
Person / Time
Site:	Limerick
Issue date:	01/02/2003
From:	Scott Wall NRC/NRR/DLPM/LPD1
To:	Skolds J Exelon Generation Co, Exelon Nuclear
Pulsifer R M, NRR/DLPM, 415-3016
References
TAC MB5507, TAC MB5508
Download: ML030030022 (14)

Text

January 2, 2003 Mr. John L. Skolds, President and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT RE: PRESSURE/TEMPERATURE CURVES (TAC NOS.

MB5507 and MB5508)

Dear Mr. Skolds:

The Commission has issued the enclosed Amendment No. 163 to Facility Operating License No. NPF-39 and Amendment No. 125 to Facility Operating License No. NPF-85 for the Limerick Generating Station, Units 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated June 26, 2002, as supplemented September 12, 2002.

These amendments would extend the use of pressure-temperature limits in TS Figure 3.4.6.1-1 for both units to 32 effective full power years.

A copy of our safety evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Scott P. Wall, Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 163 to License No. NPF-39

2. Amendment No. 125 to License No. NPF-85

3. Safety Evaluation cc w/encls: See next page

Limerick Generating Station, Units 1 & 2 cc:

Vice President, General Counsel and Chief-Division of Nuclear Safety Secretary PA Dept. of Environmental Resources Exelon Generation Company, LLC P.O. Box 8469 300 Exelon Way Harrisburg, PA 17105-8469 Kennett Square, PA 19348 Library Manager Licensing-Limerick and Peach U.S. Nuclear Regulatory Commission Bottom Region I Exelon Generation Company, LLC 475 Allendale Road Nuclear Group Headquarters King of Prussia, PA 19406 Correspondence Control P.O. Box 160 Dr. Judith Johnsrud Kennett Square, PA 19348 National Energy Committee Sierra Club Site Vice President 433 Orlando Avenue Limerick Generating Station State College, PA 16803 Exelon Generation Company, LLC P.O. Box 2300 Vice President, Licensing and Regulatory Sanatoga, PA 19464 Affairs Exelon Generation Company, LLC Plant Manager 4300 Winfield Road Limerick Generating Station Warrenville, IL 60555 Exelon Generation Company, LLC P.O. Box 2300 Director-Licensing Sanatoga, PA 19464 Mid-Atlantic Regional Operating Group Exelon Generation Company, LLC Regional Administrator, Region I Nuclear Group Headquarters U.S. Nuclear Regulatory Commission Correspondence Control 475 Allendale Road P. O. Box 160 King of Prussia, PA 19406 Kennett Square, PA 19348 Senior Resident Inspector Correspondence Control Desk U.S. Nuclear Regulatory Commission Exelon Generation Company, LLC Limerick Generating Station 200 Exelon Way, KSA 1-N-1 P.O. Box 596 Kennett Square, PA 19348 Pottstown, PA 19464 Chief Operating Officer Chairman Exelon Generation Company, LLC Board of Supervisors 4300 Winfield Road of Limerick Township Warrenville, IL 60555 646 West Ridge Pike Linfield, PA 19468 Senior Vice President, Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

Limerick Generating Station, Units 1 & 2 cc:

Vice President, Mid-Atlantic Operations Support Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Senior Vice President Mid-Atlantic Regional Operating Group Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Regulatory Assurance Manager Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464

January 2, 2003 Mr. John L. Skolds, President and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT RE: PRESSURE/TEMPERATURE CURVES (TAC NOS.

MB5507 and MB5508)

Dear Mr. Skolds:

The Commission has issued the enclosed Amendment No. 163 to Facility Operating License No. NPF-39 and Amendment No. 125 to Facility Operating License No. NPF-85 for the Limerick Generating Station, Units 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated June 26, 2002, as supplemented September 12, 2002.

These amendments would extend the use of pressure-temperature limits in TS Figure 3.4.6.1-1 for both units to 32 effective full power years.

A copy of our safety evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Scott P. Wall, Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 163 to License No. NPF-39

2. Amendment No. 125 to License No. NPF-85

3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC PDI-2 R/F JClifford SWall RPulsifer RDennig BSmith, OGC ACRS GHill (4) LLois BPlatchek, RI MOBrien SCoffin FAkstulewicz MMitchell DOCUMENT NAME: C:\ORPCheckout\FileNET\ML030030022.wpd Accession Number: ML

• see previous concurrance OFFICE PDI-2/PM PDI-2/PM PDI-2/LA SXRB* EMCB* OGC* PDI-2/SC NAME RPulsifer SWall MOBrien FAkstulewicz SCoffin BSmith JClifford DATE 12/19/02 12/20/02 12/27/02 12/10/02 11/29/02 12/13/02 12/27/02 OFFICIAL RECORD COPY

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-352 LIMERICK GENERATING STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 163 License No. NPF-39

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 26, 2002, as supplemented September 12, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-39 is hereby amended to read as follows:

Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 163, are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

James W. Clifford, Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: January 2, 2003

ATTACHMENT TO LICENSE AMENDMENT NO. 163 FACILITY OPERATING LICENSE NO. NPF-39 DOCKET NO. 50-352 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert 3/4 4-20 3/4 4-20

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 125 License No. NPF-85

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 26, 2002, as supplemented September 12, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-85 is hereby amended to read as follows:

Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 125, are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. The license amendment is effective as of its date of issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

James W. Clifford, Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: January 2, 2003

ATTACHMENT TO LICENSE AMENDMENT NO. 125 FACILITY OPERATING LICENSE NO. NPF-85 DOCKET NO. 50-353 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert 3/4 4-20 3/4 4-20

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 163 AND 125 TO FACILITY OPERATING LICENSE NOS. NPF-39 AND NPF-85 EXELON GENERATION COMPANY, LLC LIMERICK GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353

1.0 INTRODUCTION

By application dated June 26, 2002 (Reference 1), as supplemented September 12, 2002 (Reference 2), Exelon Generation Company, LLC (the licensee), requested changes to the Technical Specifications (TSs) for Limerick Generating Station (Limerick), Units 1 and 2. The supplement dated September 12, 2002, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on August 6, 2002 (67 FR 50953).

The proposed changes would extend the use of the pressure-temperature (P-T) limits in TS Figure 3.4.6.1-1 to 32 effective full power years (EFPY).

2.0 BACKGROUND

The Nuclear Regulatory Commission (NRC) staff has previously reviewed the P-T limit curves contained in Limerick Unit 1 TS Figure 3.4.6.1-1 and Limerick Unit 2 TS Figure 3.4.6.1-1. The staffs prior reviews concluded that the Limerick Unit 1 and Unit 2 P-T limit curves were acceptable for 32 EFPY of operation under the assumption that the neutron fluence (E > 1.0 MeV) at the 1/4 thickness (1/4T) depth (i.e., the throughwall location one-quarter of the way from the inside surface to the outside surface of the reactor pressure vessel (RPV)) for the units limiting RPV materials would be 1.3 x 1018 n/cm2 (neutrons/centimeter) at 32 EFPY.

However, during the staffs subsequent reviews, the adequacy of the methodology used by the licensee to determine the RPV neutron fluences was questioned and, as a result, the period of validity of the existing P-T limit curves was restricted to the end of operating cycle 10 for Limerick Unit 1 and the end of operating cycle 7 for Limerick Unit 2. It was understood that the licensee would perform updated RPV fluence calculations utilizing an NRC staff approved methodology which is consistent with the guidance in Regulatory Guide (RG) 1.190, Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence, (Reference 4) prior to the time when the restricted P-T limit curves would become invalid. Any necessary changes to the P-T limit curves would be made in order to support continued operation of the units based on the results of the licensees updated neutron fluence calculations.

3.0 REGULATORY EVALUATION

The regulatory requirements for fluence calculations are in General Design Criteria (GDC) 30 and 31 (Reference 3). The staff issued RG 1.190 in March 2001, which provided state-of-the-art calculations and measurement procedures that are acceptable to the NRC staff for determining pressure vessel fluence. The staff has approved vessel fluence calculation methodologies which satisfy the requirements of GDC 30 and 31 and are done with approved methodologies or with methods which are shown to adhere to the guidance in RG 1.190.

4.0 TECHNICAL EVALUATION

4.1 Fluence Calculational Methodology and Fluence Values In the June 26, 2002, license amendment request, the licensee submitted the results of their updated RPV neutron fluence calculations. The pressure vessel fluences were recalculated using the staff-approved method described in NEDC-32983P-A (Reference 5). The staffs review found that the method has been applied correctly. The calculated values are acceptable because they were calculated using an approved method which was applied correctly.

The original peak pressure vessel inside surface fluence was calculated to be 1.7x1018 n/cm2.

This was subsequently increased by 10% (for future power uprates) and was assumed to apply from the reactor startup rather than from the actual power uprate. In addition, the present uprate is only 5%. The 10% increase and its application from the beginning of power operation give the 32 EFPY value of the vessel fluence a significant margin of conservatism. The final fluence value for 32 EFPY used for the calculation of the P-T curves was 1.9x1018 n/cm2 or 1.3x1018 n/cm2 at the 1/4T vessel thickness. The recalculated fluence value at 1/4T is 0.89x1018 n/cm2, which gives the current P-T curves a significant margin of conservatism.

4.2 Limerick Unit 1 On January 30, 2002, the staff issued Amendment No. 155 (Reference 7), which limited the validity of the P-T curves to the end of cycle 10, estimated to occur in April 2004. Because the recalculated fluence is bounded by the fluence value used in the calculation of the present curves, extension of the validity of the P-T curves to 32 EFPY is acceptable.

4.3 Limerick Unit 2 On March 23, 2001, the staff issued Amendment No. 111 (Reference 6), which limited the validity of the P-T curves to the end of cycle 7, estimated to occur in April 2003. Because the recalculated fluence is bounded by the fluence value used in the calculation of the present curves, extension of the validity of the P-T curves to 32 EFPY is acceptable.

4.4 TS Changes The proposed TS change would eliminate a note in Figure 3.4.6.1-1 from the TSs of both units.

The note limited the applicability of the P-T curves to cycles 10 and 7 for Units 1 and 2,

respectively. The original curves for 32 EFPY, as indicated in TS Figure 3.4.6.1-1 for both units, were conservatively estimated and the removal of the note is acceptable.

5.0

SUMMARY

The staff has reviewed the Exelon submittal for Limerick Units 1 and 2 of June 26, 2002, as supplemented on September 12, 2002, with respect to the revised pressure vessel fluence values and the associated changes in the P-T curves. The staff finds that the proposed fluence values are acceptable because they were derived using staff-approved methodologies which satisfy the applicable regulatory requirements in GDC 30 and 31. In addition, the recalculated fluence bound the values used to derive the current P-T curves.

Therefore, the staff finds the P-T curves valid for 32 EFPY and the removal of the note from Figure 3.4.6.1-1 acceptable.

6.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official had no comments.

7.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (67 FR 50953). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

8.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

9.0 REFERENCES

1. Letter from M. P. Gallagher, Exelon Nuclear Corporation, to NRC, License Amendment Request LG 02-00391, Extended Use of Pressure-Temperature Limits Specified in Technical Specifications Figure 3.4.6.1-1, dated June 26, 2002.

2. Letter from M. P. Gallagher, Exelon Nuclear Corporation, to NRC, License Amendment Request LG 02-00391, Extended Use of Pressure-Temperature Limits Specified in Technical Specifications Figure 3.4.6.1 Supplemental Information, dated September 12, 2002.

3. Appendix A to 10 CFR Part 50, General Design Criterion 30, Quality of Reactor Coolant Pressure Boundary, and General Design Criterion 31, Fracture Prevention of Reactor Coolant Pressure Boundary.

4. NRC Regulatory Guide 1.190, Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence, March 2001.

5. Letter from J. F. Klapproth, GE, to Document Control Desk, NRC, Submittal of GE Proprietary Document NEDC-32983P-A, Revision 1, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluation, dated December 2001.

6. Letter from C. Gratton, NRC, to J. A. Hutton, Exelon, Limerick Generating Station, Unit 2 - Issuance of Amendment - Re: Update the Pressure-Temperature Limit Curves for Limerick Generating Station (TAC No. MB0590), dated March 23, 2001.

7. Letter from C. Gratton, NRC, to O. D. Kingsley, Exelon, Limerick Generating Station, Unit 1 - Issuance of Amendment - Re: Extended Use of the Facility Pressure-Temperature Limits and Request to Modify the Reactor Vessel Surveillance Capsule Withdrawal Schedule (TAC No. MB2933), dated January 30, 2002.

Principal Contributors: Lambros Lois Matthew Mitchell Date: January 2, 2003