ML030970732

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License Amendments 165 and 128 Relocation of Emergency Diesel Generator Maintenance Inspection Requirements. (Tacs No. MB4847 and MB4848)
ML030970732
Person / Time
Site: Limerick  
Issue date: 04/18/2003
From: Scott Wall
NRC/NRR/DLPM/LPD1
To: Skolds J
Exelon Generation Co, Exelon Nuclear
Wall, S. NRR/DLPM 415-2855
References
TAC MB4847, TAC MB4848
Download: ML030970732 (16)


Text

April 18, 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: RELOCATION OF EMERGENCY DIESEL GENERATOR MAINTENANCE INSPECTION REQUIREMENTS (TACS NO. MB4847 AND MB4848)

Dear Mr. Skolds:

The Commission has issued the enclosed Amendment No. 165 to Facility Operating License No. NPR-39 and Amendment No. 128 to Facility Operating License No. NPR-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 April 10, 2002, as supplemented by letter dated March 10, 2003.

These amendments revise the TSs to relocate emergency diesel generator maintenance inspection requirements from Section 4.8.1.1.2.e.1 to the Technical Requirements Manual.

A copy of the 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 No. 50-352 and 50-353

Enclosures:

1. Amendment No. 165 to License No. NPF-39
2. Amendment No. 128 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 Secretary Exelon Generation Company, LLC 300 Exelon Way Kennett Square, PA 19348 Manager Licensing-Limerick and Peach Bottom Exelon Generation Company, LLC Nuclear Group Headquarters Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Site Vice President Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Plant Manager Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector U.S. Nuclear Regulatory Commission Limerick Generating Station P.O. Box 596 Pottstown, PA 19464 Chairman Board of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468 Chief-Division of Nuclear Safety PA Dept. of Environmental Resources P.O. Box 8469 Harrisburg, PA 17105-8469 Library U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Vice President, Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director-Licensing Mid-Atlantic Regional Operating Group Exelon Generation Company, LLC Nuclear Group Headquarters Correspondence Control P. O. Box 160 Kennett Square, PA 19348 Correspondence Control Desk Exelon Generation Company, LLC 200 Exelon Way, KSA 1-N-1 Kennett Square, PA 19348 Chief Operating Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 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

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: RELOCATION OF EMERGENCY DIESEL GENERATOR MAINTENANCE INSPECTION REQUIREMENTS (TACS NO. MB4847 AND MB4848)

Dear Mr. Skolds:

The Commission has issued the enclosed Amendment No. 165 to Facility Operating License No. NPR-39 and Amendment No. 128 to Facility Operating License No. NPR-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 April 10, 2002, as supplemented by letter dated March 10, 2003.

These amendments revise the TSs to relocate emergency diesel generator maintenance inspection requirements from Section 4.8.1.1.2.e.1 to the Technical Requirements Manual.

A copy of the 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 No. 50-352 and 50-353

Enclosures:

1. Amendment No. 165 to License No. NPF-39
2. Amendment No. 128 to License No. NPF-85
3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC PDI-2 R/F JClifford SWall MOBrien ACRS RDennig EFields GHill (4)

OGC BPlatchek, RI ACCESSION NO. ML030970732

  • SE input provided - no major changes made OFFICE PD1-2/PM PD1-2/LA RORP/SC*

OGC PDI-2/SC NAME SWall MOBrien RDennig RWeisman JBoska for JClifford DATE 3/14/03 3/17/03 SE dated 01/21/03 04/02/03 4/17/03 Official Record Copy

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-352 LIMERICK GENERATING STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 165 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 April 10, 2002, as supplemented by letter dated March 10, 2003, 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:

(2)

Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 165, are hereby incorporated into this license. Exelon Generation Company, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of the date of issuance and shall be implemented within 30 days of issuance. Implementation shall include the relocation of the emergency diesel generator maintenance requirements of Technical Specification 4.8.1.1.2.e.1 to the Technical Requirements Manual as identified in the licensees application dated April 10, 2002, as supplemented by letter dated March 10, 2003, and reviewed in the staffs safety evaluation enclosed with this amendment.

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: April 18, 2003

ATTACHMENT TO LICENSE AMENDMENT NO. 165 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 8-4 3/4 8-4

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 128 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 April 10, 2002, as supplemented by letter dated March 10, 2003, 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:

(2)

Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 128, are hereby incorporated into this license. Exelon Generation Company, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of the date of issuance and shall be implemented within 30 days of issuance. Implementation shall include the relocation of the emergency diesel generator maintenance requirements of Technical Specification 4.8.1.1.2.e.1 to the Technical Requirements Manual as identified in the licensees application dated April 10, 2002, as supplemented by letter dated March 10, 2003, and reviewed in the staffs safety evaluation enclosed with this amendment.

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: April 18, 2003

ATTACHMENT TO LICENSE AMENDMENT NO. 128 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 8-4 3/4 8-4

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 165 AND 128 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 letter dated April 10, 2002, as supplemented by letter dated March 10, 2003, Exelon Generation Company, LLC (the licensee), requested changes to the Technical Specifications (TSs) for Limerick Generating Station, Units 1 and 2 (LGS-1 and 2). The proposed changes would revise the TSs to relocate emergency diesel generator (EDG) maintenance inspection requirements from LGS-1 and 2 TSs to the Technical Requirements Manual (TRM). This document is controlled in accordance with the requirements of Title 10 of the Code of Federal Regulations, Part 50, Section 59 (10 CFR 50.59), Changes, tests, and experiments.

The supplement dated March 10, 2003, 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 May 28, 2002 (67 FR 36926).

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act requires that TSs be included in nuclear power plant operating licenses. In 10 CFR 50.36, the Nuclear Regulatory Commission (NRC, or Commission) established its regulatory requirements related to the content of the TSs.

Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. As a result, existing TS requirements that fall within or satisfy any of the criteria of 10 CFR 50.36 must be retained in the TSs, while those TS requirements that do not fall within or satisfy these criteria may be relocated to other licensee-controlled documents.

Consistent with the requirements of 10 CFR 50.36, the relocation of the maintenance inspection requirements for EDGs to licensee-controlled documents was generically approved for incorporation into standard technical specifications (STS) by the NRC (reference: NUREG-1430, Standard Technical Specifications, Babcock and Wilcox Plants, and NUREG-1433, Standard Technical Specifications, General Electric Plants (BWR/4)). Changes to licensee-controlled documents are controlled under 10 CFR 50.59.

Pursuant to 10 CFR 50.65, performance and condition monitoring activities and associated goals and preventive maintenance activities shall be evaluated at least every refueling cycle provided the interval between evaluations does not exceed 24 months. The evaluations shall take into account, where practical, industry-wide operating experience.

3.0 TECHNICAL EVALUATION

The licensee proposed to revise the EDG SRs of the facility. Specifically, the licensee proposed to delete the following wording (in italics) from the TSs:

Limerick Units 1 and 2, Section 3/4.8, Electrical Power Systems, Specification 4.8.1.1.2.e.1, Every 24 months subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with the Fairbanks Morse Owners Group recommendations and its manufacturers recommendations for this class of standby service.

The licensee proposed to relocate the subject EDG inspection requirements to licensee-controlled documents. The licensee stated that the EDG inspection is a preventive maintenance requirement that is implemented through the licensees 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 continue to be maintained in the TS.

As stated in Section 2.0 above, the relocation of the maintenance inspection requirements for EDGs to licensee-controlled documents was generically approved for incorporation into the STS in NUREG-1430 as consistent with the requirements of 10 CFR 50.36 by the NRC.

Accordingly, the NRC staff reviewed the licensees proposed relocation of the subject EDG inspection requirements from the LGS-1 and 2 TSs to licensee-controlled documents. The NRC staff finds that:

1.

The EDG inspection is a preventive maintenance requirement that is implemented through the licensees 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.

2.

The inspection is not required to assure that the necessary quality of the EDG is maintained. Rather, EDG operability is verified by the SRs that continue to be maintained in the TSs.

3.

The proposed changes are consistent with 10 CFR 50.36 and the Standard Technical Specifications.

4.

Relocated EDG inspection requirements will be controlled under the requirements of 10 CFR 50.59, Changes, tests, and experiments.

Based on the above evaluation, the NRC staff finds the proposed license amendment requests acceptable.

4.0 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.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a surveillance requirement. 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 36926). 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 amendment.

6.0 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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: E. Fields Date: April 18, 2003