ML051650051
| ML051650051 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/25/2005 |
| From: | Travis Tate NRC/NRR/DLPM/LPD1 |
| To: | Crane C Exelon Generation Co |
| Tate T, NRR/DLPM, 415-8474 | |
| References | |
| TAC MC2739, TAC MC2740 | |
| Download: ML051650051 (15) | |
Text
July 25, 2005 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: RELOCATE ADMINISTRATIVE CONTROL REQUIREMENTS (TAC NOS. MC2739 AND MC2740)
Dear Mr. Crane:
The Commission has issued the enclosed Amendment No. 176 to Facility Operating License No. NPF-39 and Amendment No. 138 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 April 8, 2004.
These amendments relocate several TSs from Section 6, Administrative Controls, requirements to the Quality Assurance Topical Report. Specifically, the amendments relocate (1) the Plant Operations Review Committee and Nuclear Review Board requirements, (2) the program/procedure review and approval requirements, and (3) the record-retention requirements.
A copy of our safety evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Travis L. Tate, 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. 176 to License No. NPF-39
- 2. Amendment No. 138 to License No. NPF-85
- 3. Safety Evaluation cc w/encls: See next page
Limerick Generating Station, Unit Nos. 1 and 2 cc:
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 Regulatory Assurance Manager - Limerick Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Senior Vice President - Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Operations, Mid-Atlantic Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Vice President Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director Licensing and Regulatory Affairs Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Manager Licensing Limerick Generating Station Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Associate General Counsel Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Correspondence Control Desk Exelon Generation Company, LLC P.O. Box 160 Kennett Square, PA 19348 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 Library U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 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
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: RELOCATE ADMINISTRATIVE CONTROL REQUIREMENTS (TAC NOS. MC2739 AND MC2740)
Dear Mr. Crane:
The Commission has issued the enclosed Amendment No. 176 to Facility Operating License No. NPF-39 and Amendment No. 138 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 April 8, 2004.
These amendments relocate several TSs from Section 6, Administrative Controls, requirements to the Quality Assurance Topical Report. Specifically, the amendments relocate (1) the Plant Operations Review Committee and Nuclear Review Board requirements, (2) the program/procedure review and approval requirements, and (3) the record-retention requirements.
A copy of our safety evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Travis L. Tate, 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. 176 to License No. NPF-39
- 2. Amendment No. 138 to License No. NPF-85
- 3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
PUBLIC PDI-2 R/F DRoberts TTate MOBrien MShanbaky, RI OGC ACRS GHill (4)
TBoyce DLPM DPR Accession Number: ML051650051 OFFICE PDI-2/PM PDI-2/LA IROB/SC OGC PDI-2/SC NAME TTate MOBrien TBoyce JHull DRoberts DATE 6/23/05 6/16/05 6/23/05 6/29/05 7/22/05 Official Record Copy
EXELON GENERATION COMPANY, LLC DOCKET NO. 50-352 LIMERICK GENERATING STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 176 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 8, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's 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. 176, 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 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Darrell J. Roberts, 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: July 25, 2005
ATTACHMENT TO LICENSE AMENDMENT NO. 176 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 xxvi xxvi xxvii xxvii 6-7 6-7 6-8 6-8 6-9 6-9 6-10 6-10 6-12 6-12 6-12a 6-12a 6-13 6-13 6-19 6-19 6-20 6-20 6-21a 6-21a 6-22 6-22
EXELON GENERATION COMPANY, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 138 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 8, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's 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. 138, 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 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Darrell J. Roberts, 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: July 25, 2005
ATTACHMENT TO LICENSE AMENDMENT NO. 138 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 xxvi xxvi xxvii xxvii 6-7 6-7 6-8 6-8 6-9 6-9 6-10 6-10 6-12 6-12 6-12a 6-12a 6-13 6-13 6-19 6-19 6-20 6-20 6-21a 6-21a 6-22 6-22
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 176 AND 138 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 April 8, 2004 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML041110042) Exelon Generation Company, LLC (Exelon or the licensee), requested changes to the Technical Specifications (TSs) for Limerick Generating Station (LGS), Units 1 and 2. The proposed changes would revise LGS, Units 1 and 2, TSs Section 6, Administrative Controls, by relocating (1) the Plant Operations Review Committee (PORC) and Nuclear Review Board (NRB) requirements, (2) the program/procedure review and approval requirements, and (3) the record-retention requirements to the Exelon/AmerGen Energy Company, LLC, Quality Assurance Topical Report (QATR). Specifically, the proposed change would relocate the requirements of TS 6.5, Review and Audit, TSs 6.8.2 and 6.8.3, and TS 6.10, Record Retention, to the QATR. Additionally, the reference to the record retention requirements in TS 6.13.1.a and TS 6.14.1.a for the Process Control Program (PCP) and the Offsite Dose Calculation Manual (ODCM), respectively, would be deleted for consistency with the proposed changes to TS 6.10. The TS Index Section will also be modified to reflect the removal of the associated TS sections.
2.0 REGULATORY EVALUATION
Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. In Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36 (10 CFR 50.36), the Commission established regulatory requirements related to the content of TSs. This regulation requires that the TSs include items in eight specific categories. These categories include 1) safety limits, limiting safety system settings, and limiting control settings, 2) limiting conditions for operation (LCOs), 3) surveillance requirements (SRs), 4) design features, 5) administrative controls, 6) decommissioning,
- 7) initial notification, and 8) written reports. However, the regulation does not specify the particular requirements to be included in a plants TSs.
The U.S. Nuclear Regulatory Commission (NRC) developed criteria, as described in the Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors (58 FR 39132), to determine which design conditions and associated surveillances should be located in the TSs as LCOs. Four criteria were subsequently incorporated into the regulations by an amendment to 10 CFR 50.36 (60 FR 36953) and are as follows:
(1) Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
(2) A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
(3) A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
(4) A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
The Commissions Final Policy Statement and documentation related to the revision of 10 CFR 50.36 acknowledged that implementation of these criteria may permit some requirements presently in the TSs to be relocated to other licensee-controlled documents and programs.
On December 12, 1995, the NRC issued Administrative Letter (AL) 95-06, to inform licensees of experiences involving the relocation of TS administrative controls related to quality assurance. In AL 95-06, the NRC staff identified typical TS administrative controls that may be relocated to licensee quality assurance control documents subject to the controls of 10 CFR 50.54(a). TS administrative controls requirements identified in AL 95-06 include the independent safety engineering group, reviews and audits, the procedure review process, and records and record retention.
The NRC staff reviewed the TSs proposed to be relocated for compliance with 10 CFR 50.36 and agreement with the precedent as established in NUREG-1433, Rev. 2, Standard Technical Specifications, General Electric Plants, BWR/4," for boiling-water reactors (BWRs). The NRC staff review also ensured that future changes to relocated TSs requirements will receive appropriate regulatory control.
3.0 TECHNICAL EVALUATION
3.1 Proposed Changes LGS TS Section 6 contains administrative controls requirements in accordance with 10 CFR 50.36(c)(5). In its application, the licensee proposed to relocate the entire TSs 6.5 and 6.10 and TS Sections 6.8.2 and 6.8.3 to the QATR. The licensee stated that the QATR is the controlling document for their quality assurance program, which includes LGS Units 1 and 2.
Consistent with the proposed change to TS 6.10, the licensee also proposed to modify TSs 6.13.1.a and 6.14.1.a by deleting the reference to the record retention requirements for the PCP and ODCM. The licensee proposes to replace the deleted portions of TSs 6.13.1.a and 6.14.1.a with the wording with the following information:. In addition, the licensee proposed to control subsequent changes to the relocated requirements in accordance with 10 CFR 50.54(a).
The TS Index Section would also be modified to reflect the removal of the associated TS sections.
3.2 Evaluation TS 6.5 contains requirements for the PORC and NRB. The NRC staff has reviewed the proposed changes to TS 6.5 and determined that these requirements contain detailed information related to the function, composition, processes, and responsibilities of organizations established to perform reviews and audits related to quality assurance. Therefore, the NRC staff has determined that the requirements are consistent with those identified in AL 95-06 for relocation to licensee quality assurance control documents.
TSs 6.8.2 and 6.8.3 contain procedural requirements. The NRC staff has reviewed the proposed changes to TSs 6.8.2 and 6.8.3 and determined that these requirements are related to the processes for the review and approval of procedures and changes to procedures.
Therefore, the NRC staff has determined that the requirements are consistent with those identified in AL 95-06 for relocation to the quality assurance plan.
TS 6.10 contains requirements for record retention. The NRC staff has reviewed the proposed changes to TS 6.10 and determined that these requirements are related to the duration of retention for various types of records. Therefore, the NRC staff has determined that the requirements are consistent with those identified in AL 95-06 for relocation to the quality assurance plan.
TSs 6.13.1.a and 6.14.1.a contain requirements for the PCP and the ODCM. The NRC staff has reviewed the proposed changes to TSs 6.13.1.a and 6.14.1.a and determined that the deletion of the reference to the record retention requirements in TS 6.10 is consistent with the proposed relocation of the requirements to the QATR. The addition of the wording with the following information: to these TSs is editorial in nature and does not change the meaning of the remaining portion of the requirements.
The NRC staff reviewed the proposed changes to the TS Index and determined that the changes are administrative in nature and are consistent with the proposed changes to the TS requirements.
3.3 Conclusion The NRC staff has reviewed the licensees proposed changes to TSs 6.5, 6.8.2, 6.8.3, and 6.10 against the criteria for administrative controls set forth in 10 CFR 50.36(c)(5). Section 50.36(c)(5) of 10 CFR states, administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. The NRC staff has determined that the content of the proposed changes involves administrative controls related to quality assurance requirements. In addition, the NRC staff determined that the proposed changes do not involve reductions in administrative controls that assure operation of the facility in a safe manner.
Therefore, the proposed changes involve requirements that do not satisfy the criteria of 10 CFR 50.36 for inclusion in the TSs. The relocated requirements will be directly controlled by regulations in accordance with 10 CFR 50.54(a) or 10 CFR 50.59. Further, the NRC staff determined proposed changes are consistent with the requirements identified for relocation to the quality assurance plan by AL 95-06 and are also consistent with the requirements in NUREG-1433. Therefore, the NRC staff concludes that the proposed changes to TSs 6.5, 6.8.2, 6.8.3, and 6.10 are acceptable.
The NRC staff has reviewed the proposed modifications to TSs 6.13.1.a, and 6.14.1.a and determined that the changes are acceptable because the deletion of the reference to TS 6.10 is consistent with the relocation of the TSs to the QATR. In addition, the NRC staff determined that the addition of the wording with the following information: is editorial in nature and does not change the meaning of the remaining portion of the requirements. Therefore, the NRC staff concludes that the proposed changes are acceptable.
The NRC staff reviewed the proposed changes to the TS Index and determined that the changes are administrative in nature and are consistent with the proposed changes to the TS requirements. Therefore, the NRC staff concludes that the proposed changes are acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's 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 relate to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). 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 Commission's 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 Contributor: T. Tate Date: July 25, 2005