ML081190546
| ML081190546 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/28/2008 |
| From: | Peter Bamford NRC/NRR/ADRO/DORL/LPLI-2 |
| To: | Chernoff H NRC/NRR/ADRO/DORL/LPLI-2 |
| Bamford, Peter J., NRR/DORL 415-2833 | |
| References | |
| TAC MD7508, TAC MD7509 | |
| Download: ML081190546 (4) | |
Text
April 28, 2008 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
Peter Bamford, Project Manager /ra/
Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - ELECTRONIC TRANSMISSION, DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING TECHNICAL SPECIFICATION ADMINISTRATIVE CHANGE AMENDMENTS (TAC NOS. MD7508 AND MD7509)
The attached draft request for additional information (RAI) was transmitted by electronic transmission on April 25, 2008, to Mr. Glenn Stewart, at Exelon Generation Company, LLC (Exelon). This draft RAI was transmitted to facilitate the technical review being conducted by the Nuclear Regulatory Commission (NRC) staff and to support a conference call (if needed) with Exelon in order to clarify the licensees submittal. The draft RAI is related to Exelons submittal dated December 12, 2007, regarding Limerick Generating Station, Units 1 and 2, Proposed Administrative Changes to Technical Specifications. The draft questions were sent to ensure that they were understandable, the regulatory basis was clear, and to determine if the information was previously docketed. Additionally, review of the draft RAI would allow Exelon to evaluate and agree upon a schedule to respond to the RAI. This memorandum and the attachment do not represent an NRC staff position.
Docket Nos. 50-352 and 50-353
Enclosure:
As stated
April 28, 2008 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
Peter Bamford, Project Manager /ra/
Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - ELECTRONIC TRANSMISSION, DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING TECHNICAL SPECIFICATION ADMINISTRATIVE CHANGE AMENDMENTS (TAC NOS. MD7508 AND MD7509)
The attached draft request for additional information (RAI) was transmitted by electronic transmission on April 25, 2008, to Mr. Glenn Stewart, at Exelon Generation Company, LLC (Exelon). This draft RAI was transmitted to facilitate the technical review being conducted by the Nuclear Regulatory Commission (NRC) staff and to support a conference call (if needed) with Exelon in order to clarify the licensees submittal. The draft RAI is related to Exelons submittal dated December 12, 2007, regarding Limerick Generating Station, Units 1 and 2, Proposed Administrative Changes to Technical Specifications. The draft questions were sent to ensure that they were understandable, the regulatory basis was clear, and to determine if the information was previously docketed. Additionally, review of the draft RAI would allow Exelon to evaluate and agree upon a schedule to respond to the RAI. This memorandum and the attachment do not represent an NRC staff position.
Docket Nos. 50-352 and 50-353
Enclosure:
As stated DISTRIBUTION:
Public RidsNrrPMPBamford LPL1-2 R/F Accession No.: ML081190546 OFFICE LPL1-2/PM NAME PBamford DATE 4/28/08
OFFICIAL RECORD COPY
Draft REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED ADMINISTRATIVE CHANGES TO THE TECHNICAL SPECIFICATIONS LIMERICK GENERATING STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-352 AND 50-353 By letter dated December 12, 2007, (Agencywide Documents Access and Management System Accession No. ML073461114) Exelon Generation Company, LLC, submitted a license amendment request (LAR) regarding various administrative changes to the technical specifications (TSs) for Limerick Generating Station (LGS), Units 1 and 2.
The Nuclear Regulatory Commission (NRC) Staff has been reviewing the submittal and has determined that additional information is needed to complete its review.
Section 4.0 of the LAR describes changes to several TS pages where relocation references are proposed to be changed from the Updated Final Safety Analysis Report (UFSAR) to the Technical Requirements Manual (TRM). Item 4 in LAR section 4.0, states that the LGS TRM is incorporated into the LGS UFSAR by reference. The LGS UFSAR, section 1.6, titled Material Incorporated by Reference/General Reference does not list the TRM as a document incorporated by reference. Furthermore, the discussion of the TRM in UFSAR section 13.5.3 does not state that the TRM is incorporated by reference. Nuclear Energy Institute (NEI) 98-03, Guidelines for Updating Final Safety Analysis Reports, revision 1, dated June 1999, provides instructions on the proper way to incorporate material by reference into the UFSAR. U.S. NRC Regulatory Guide (RG) 1.181, revision 0, dated September 1999, titled Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50.71 (e) endorses NEI 98-03, revision 1. RG 1.181, revision 0, is in turn endorsed by the LGS UFSAR in section 1.8.
NEI 98-03 discusses the relationship of the TRM to the UFSAR and describes two options for TRM control. Under option (1), the TRM is incorporated by reference into the UFSAR. With option (2), the TRM is treated in a manner consistent with procedures fully or partially described in the UFSAR. Option (1) requires an explicit UFSAR statement of incorporation by reference.
It also requires the TRM to be subject to the update/reporting requirements of 10 CFR 50.71(e).
With option (2), the important consideration is the treatment of the TRM such that its contents are considered as UFSAR level information when evaluating changes under 10 CFR 50.59. LGS UFSAR 13.5.3 refers to control of the TRM under 10 CFR 50.59 but does not clearly specify that information contained in the TRM is UFSAR level material.
Based on this discussion please answer the following:
1.)
Is it your intent to consider the TRM incorporated by reference into the UFSAR in accordance with the process described in NEI 98-03, or do you plan to control the TRM in accordance with option (2) described above? If you plan to use option (2) will you treat the TRM consistent with procedures fully or partially described in the UFSAR? Also, if option (2) is desired, do you plan to update your UFSAR section 13.5.3 to clearly specify the treatment of TRM material as described in the final safety analysis report, as updated under 10 CFR 50.59.?
Additionally, the following administrative issue is provided for your consideration.
2.)
LGS Unit 1 TS page 3/4 1-12 proposes to delete paragraph 4.1.3.6(d) but does not propose to move the and from 4.1.3.6(c) to 4.1.3.6(b). Please consider submitting a corrected TS page to address this grammatical issue.