ML040830735

License Amendment, Issuance of Amendment Generic Letter 88-01 Requirements

ML040830735
Person / Time
Site:	Limerick
Issue date:	04/20/2004
From:	Scott Wall NRC/NRR/DLPM/LPD1
To:	Crane C Exelon Generation Co, Exelon Nuclear
Wall, S. NRR/DLPM 415-2855
Shared Package
ML040830738	List: ML040830735
References
GL-88-001, TAC MB9884, TAC MC9885
Download: ML040830735 (13)

Text

April 20, 2004 Mr. Christopher M. Crane, 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: GENERIC LETTER 88-01 REQUIREMENTS (TAC NOS. MB9884 AND MB9885)

Dear Mr. Crane:

The Commission has issued the enclosed Amendment No. 171 to Facility Operating License No. NPF-39 and Amendment No. 133 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 27, 2003.

These amendments revise TS 4.0.5.f and associated Bases, and Bases Section 3/4.4.8, with regard to the commitment to perform piping inspections in accordance with Generic Letter 88-01, by adding the words "or in accordance with alternate measures approved by the NRC staff."

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 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. 171 to License No. NPF-39

2. Amendment No. 133 to License No. NPF-85

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

Limerick Generating Station, Units 1 & 2 cc:

Chief Operating Officer Director Licensing Exelon Generation Company, LLC Exelon Generation Company, LLC 4300 Winfield Road Nuclear Group Headquarters Warrenville, IL 60555 Correspondence Control P. O. Box 160 Site Vice President Kennett Square, PA 19348 Limerick Generating Station Exelon Generation Company, LLC Manager Licensing P.O. Box 2300 Limerick and Peach Bottom Sanatoga, PA 19464 Exelon Generation Company, LLC Nuclear Group Headquarters Plant Manager Correspondence Control Limerick Generating Station P.O. Box 160 Exelon Generation Company, LLC Kennett Square, PA 19348 P.O. Box 2300 Sanatoga, PA 19464 Vice President General Counsel and Secretary Regulatory Assurance Manager - Limerick Exelon Generation Company, LLC Exelon Generation Company, LLC 2301 Market Street, S23-1 P.O. Box 2300 Philadelphia, PA 19101 Sanatoga, PA 19464 Correspondence Control Desk Senior Vice President - Nuclear Services Exelon Generation Company, LLC Exelon Generation Company, LLC 200 Exelon Way, KSA 1-N-1 4300 Winfield Road Kennett Square, PA 19348 Warrenville, IL 60555 Regional Administrator, Region I Vice President - Mid-Atlantic Operations U.S. Nuclear Regulatory Commission Exelon Generation Company, LLC 475 Allendale Road 200 Exelon Way, KSA 3-N King of Prussia, PA 19406 Kennett Square, PA 19348 Senior Resident Inspector Vice President - Operations Support U.S. Nuclear Regulatory Commission Exelon Generation Company, LLC Limerick Generating Station 4300 Winfield Road P.O. Box 596 Warrenville, IL 60555 Pottstown, PA 19464 Vice President Library Licensing and Regulatory Affairs U.S. Nuclear Regulatory Commission Exelon Generation Company, LLC Region I 4300 Winfield Road 475 Allendale Road Warrenville, IL 60555 King of Prussia, PA 19406

Limerick Generating Station, Units 1 & 2 cc:

Chief-Division of Nuclear Safety PA Dept. of Environmental Resources P.O. Box 8469 Harrisburg, PA 17105-8469 Chairman Board of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803

April 20, 2004 Mr. Christopher M. Crane, 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: GENERIC LETTER 88-01 REQUIREMENTS (TAC NOS. MB9884 AND MB9885)

Dear Mr. Crane:

The Commission has issued the enclosed Amendment No. 171 to Facility Operating License No. NPF-39 and Amendment No. 133 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 27, 2003.

These amendments revise TS 4.0.5.f and associated Bases, and Bases Section 3/4.4.8, with regard to the commitment to perform piping inspections in accordance with Generic Letter 88-01, by adding the words "or in accordance with alternate measures approved by the NRC staff."

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 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. 171 to License No. NPF-39

2. Amendment No. 133 to License No. NPF-85

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

PUBLIC PD1-2 R/F JClifford SWall MOBrien TChan OGC ACRS GHill (4) TBoyce WKoo CBixler, RGN-I Accession Number: ML040830735 TS(s): ML

• Safety Evaluation dated February 18, 2004 Package: ML040830738 ** See previous concurrence OFFICE PDI-2/PM SRXB/SC* IROB/SC** PDI-2/LA OGC** PDI-2/SC NAME SWall TChan TBoyce MOBrien GLongo VNerses for JClifford DATE 4/12/04 2/18/04 4/2/04 4/19/04 4/8/04 4/16/04 OFFICIAL RECORD COPY

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-352 LIMERICK GENERATING STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 171 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 27, 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:

Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 171, 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 by VNerses for/

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 20, 2004

ATTACHMENT TO LICENSE AMENDMENT NO. 171 FACILITY OPERATING LICENSE NO. NPF-39 DOCKET NO. 50-352 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert 3/4 0-3 3/4 0-3 B 3/4 0-6 B 3/4 0-6 B 3/4 4-6 B 3/4 4-6

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 133 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 27, 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:

Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 133, 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 by VNerses for/

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 20, 2004

ATTACHMENT TO LICENSE AMENDMENT NO. 133 FACILITY OPERATING LICENSE NO. NPF-85 DOCKET NO. 50-353 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert 3/4 0-3 3/4 0-3 B 3/4 0-6 B 3/4 0-6 B 3/4 4-6 B 3/4 4-6

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 171 AND 133 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 27, 2003, Exelon Generation Company, LLC (EGC or 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 modify TS 4.0.5.f and associated Bases, and Bases Section 3/4.4.8, with regard to the commitment to perform piping inspections in accordance with Generic Letter (GL) 88-01, by adding the words "or in accordance with alternate measures approved by the NRC staff."

2.0 REGULATORY EVALUATION

The Nuclear Regulatory Commission (NRC) staff determined that EGC, in its June 27, 2003, submittal, identified the applicable regulatory requirements. The regulatory requirements for which the NRC staff based its acceptance are described below.

GL 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping," dated January 25, 1988, outlined the NRC staffs position regarding Intergranular Stress Corrosion Cracking (IGSCC) problems. Specifically, GL 88-01 addressed IGSCC problems in Boiling Water Reactor (BWR) piping made of austenitic stainless steel that is 4 inches or larger in nominal diameter and contains reactor coolant at a temperature above 200 EF during reactor power operation regardless of American Society of Mechanical Engineers, Boiler and Pressure Vessel Code (ASME Code) classification. Pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.54(f), (10 CFR 50.54(f)), GL 88-01 requested licensees of operating BWRs and holders of construction permits for BWRs to provide information regarding conformance with the NRC positions. One item that the GL requested licensees to address was a TS change to include a statement in the TS section on Inservice Inspection (ISI) that the ISI program for piping covered by the scope of GL 88-01 will be in conformance with the NRC positions on inspection schedules, methods and personnel, and sample expansion included in the GL.

NUREG-0313, "Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping," Revision 2, dated January 1988, provided the technical bases for the positions included in GL 88-01.

Electrical Power Research Institutes proprietary report TR-113932, "BWR Vessel and Internals Project, Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedule (BWR VIP-75)," dated October 1999, proposed revisions to the extent and frequencies for piping inspections contained in GL 88-01. The BWRVIP-75 report was supplemented by letter dated August 28, 2001, in response to the open items in the NRC staff's initial safety evaluation (SE),

dated September 15, 2000. In the NRC staff's final SE, dated May 14, 2002, the staff found that the revised BWRVIP-75 report could be used in lieu of the inspection guidance in GL 88-01 and NUREG-0313, Revision 2, or as the technical basis for a plant-specific request for a license amendment to change TSs requiring GL 88-01 or NUREG-0313, Revision 2, inspections.

Pursuant to 10 CFR 50.36, each licensee authorizing operation of a production or utilization facility must include TSs. In April 2001, the NRC issued NUREG-1433, "Standard Technical Specifications [STSs], General Electric, BWR/4," Revision 2. The STSs were developed based on criteria outlined in 10 CFR 50.36. NUREG-1433 was established as a general model for developing potential TSs for General Electric BWR/4 plants. The generic Bases presented in NUREG-1433 provide information regarding the application of the TS criteria and reflect detailed system configurations and operating characteristics for all reactor designs.

3.0 TECHNICAL EVALUATION

EGC proposed to revise the TSs for LGS-1 and 2 by adding "or in accordance with alternate measures approved by the NRC staff" to the end of the first sentence in Surveillance Requirement (SR) 4.0.5.f, "Applicability." SR 4.0.5.f establishes the commitment that the ISI program for piping identified in GL 88-01 shall be performed in accordance with the NRC staff's positions on schedules, methods and personnel, and sample expansion included in the GL.

Additionally, EGC proposed to revise TS Bases Specification 4.0.5 and TS Bases Section 3/4.4.8, "Structural Integrity," to include reference to the use of other alternate measures approved by the NRC staff. The NRC staff has reviewed the licensees proposed changes against the original 10 CFR 50.54(f) request presented in GL 88-01.

The proposed changes will allow the licensee to employ alternate measures approved by the NRC staff in lieu of the GL 88-01 inspection guidance. The BWRVIP-75 report was provided to replace the guidance for the extent and frequencies of piping inspections contained in GL 88-01. As discussed in the NRC staffs SE for the revised BWRVIP-75 report, the staff approved the use of BWRVIP-75 in lieu of the inspection guidance in GL 88-01 and NUREG-0313, Revision 2, or as the technical basis for a plant-specific request for a license amendment to change TSs requiring GL 88-01 or NUREG-313, Revision 2, inspections. The proposed changes would allow the licensee to use the inspection guidance provided in the revised BWRVIP-75 report.

The NRC staff notes that NUREG-1433, Revision 2, no longer requires the commitment to IGSCC inspection in accordance with GL-88-01 to be included in the TSs. As such, for plants using the STS format, the IGSCC inspection commitment does not need to be in the TSs. This is consistent with the guidance provided in GL 88-01 which allows the IGSCC inspection requirements to be removed from the TSs when the ISI section is removed from the TSs.

Therefore, it is appropriate to have provisions in the TSs to allow the use of approved alternate measures for IGSCC inspections in lieu of GL 88-01 requirements.

The NRC staff also notes that NUREG-1433, Revision 0, dated September 1992, contained the same wording currently proposed by the licensee. Additionally the same wording was approved by the staff for use at other plants to implement the ISI program for piping as identified in GL 88-01. The NRC staffs SEs for James A. FitzPatrick, dated July 1, 1991, Oyster Creek, dated September 12, 1991, and Hope Creek, dated June 1, 1992, provide precedents of approval for using such wording at other plants.

The NRC staff has reviewed the request by EGC to revise the TSs for LGS-1 and 2. The changes are generally in accordance with the model TS and wording in GL 88-01. Based on the review, the staff concludes that the proposed TS changes meet the intent of GL 88-01, will not affect the level of quality and safety of the ISI program at LGS-1 and 2 and, therefore, are 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 requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. 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 (68 FR 49817). 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.

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

Principal Contributors: W. Koo S. Wall Date: April 20, 2004