ML13023A410

Issuance of Amendments Relocation of Technical Specifications for Motor-Operated Valve Thermal Overload Protection

ML13023A410
Person / Time
Site:	Limerick
Issue date:	03/19/2013
From:	Richard Ennis Plant Licensing Branch 1
To:	Pacilio M Exelon Nuclear
Ennis R NRR/DORL/LPL1-2 301-415-1420
References
TAC ME9939, TAC ME9940
Download: ML13023A410 (21)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 19, 2013 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: RELOCATION OF TECHNICAL SPECIFICATIONS FOR MOTOR-OPERATED VALVE THERMAL OVERLOAD PROTECTION (TAC NOS. ME9939 AND ME9940)

Dear Mr. Pacilio:

The Commission has issued the enclosed Amendment Nos. 209 and 170 to Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station, Units 1 and 2, respectively.

These amendments consist of changes to the Technical Specifications and Facility Operating Licenses in response to your application dated November 14, 2012.

The amendments relocate the Technical Specification (TS) requirements for motor-operated valve thermal overload protection from the TSs to the Technical Requirements Manual.

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

Sincerely, Richard B. Ennis, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 209 to License No. NPF-39

2. Amendment No. 170 to License No. NPF-85

3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-352 LIMERICK GENERATING STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 209 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 November 14,2012, 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

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. 209, are hereby incorporated into this 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. Implementation shall include the relocation of information from the Technical Specifications to the Technical Requirements Manual as described in the licensee's application dated November 14, 2012.

FOR THE NUCLEAR REGULATORY COMMISSION Meena K. Khanna, Chief Plant Licensing Branch 1-2 Division of Operating Reactor licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance:

March 19, 2013

ATTACHMENT TO LICENSE AMENDMENT NO. 209 FACILITY OPERATING LICENSE NO. NPF-39 DOCKET NO. 50-352 Rep/ace the following page of the Facility Operating License with the revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.

Remove Insert Page 3 Page 3 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 xv xv 3/48-27 3/48-27

-3 (3)

Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)

Pursuant to the Act and 10 CFR Parts 30, 40,70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)

Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility, and to receive and possess, but not separate, such source, byproduct, and special nuclear materials as contained in the fuel assemblies and fuel channels from the Shoreham Nuclear Power Station.

C.

This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I (except as exempted from compliance in Section 2.0. below) and is subject to aU applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level Exelon Generation Company is authorized to operate the facility at reactor core power levels not in excess of 3515 megawatts thermal (100% rated power) in accordance with the conditions specified herein and in Attachment 1 to this license. The items identified in Attachment 1 to this license shall be completed as specified. Attachment 1 is hereby incorporated into this license.

(2)

Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised throLlgh Amendment No. 209, are hereby incorporated into this license.

Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Amendment No. 62, -+00, ~, W, 2G+, 209

ELECTRICAL POWER SYSTEMS (Continued)

Table 4.8.2.

Battery Surveillance Requirements........................ 3/4 8-13 J.C. Sources Shutdown.................................... 3/4 8 14 3/4.8.3 ONSITE POWER DISTRIBUTION SYSTEMS Distribution Operating................................... 3/4 8-15 Distribution Shutdown.................................... 3/4 8 18 3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES (Deleted).................................................. 3/4 8 21 (Deleted).................................................. 3/4 8-27 Reactor Protecti on System El ectri c Power Moni tori ng........ 3/4 8 28 3/4.9 REFUELING OPERATIONS 3/4.9.1 REACTOR MODE SWITCH........................................ 3/4 9 3/4.9.2 INSTRUMENTATION............................................ 3/4 9 3 3/4.9.3 CONTROL ROD POSITION....................................... 3/4 9-5 3/4.9.4 DECAY TIME................................................. 3/4 9-6 3/4.9.5 COMMUNICATIONS............................................. 3/4 9 7 3/4.9.6 REFUELING PLATFORM......................................... 3/4 9-8 3/4.9.7 CRANE TRAVEL -

SPENT FUEL STORAGE POOL..................... 3/4 9 10 3/4.9.8 WATER LEVEL REACTOR VESSEL............................... 3/4 9-11 3/4.9.9 WATER LEVEL -

SPENT FUEL STORAGE POOL...................... 3/4 9 12 L:MERICK UNIT 1 xv Amendment No. YJ, 209

PAG' INTENTIONALLY LEFT BLANK LIMER CK - UNIT 1 3/4 8 27 Amendment No. ++/-, +&, 209

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 EXELON GENERATION COMPANY. LLC DOCKET NO. 50-353 LIMERICK GENERATING STATiON, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 170 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 November 14, 2012, 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 appllcation, 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 pi..lblic;,and E.

The issuance of this amendment is in accordance with '10 C FR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

- 2

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. 170, are hereby incorporated into this 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. Implementation shall include the relocation of information from the Technical Specifications to the Technical Requirements Manual as described in the licensee's application dated November 14, 2012.

FOR THE NUCLEAR REGULATORY COMMISSION

~~

Meena K. Khanna, Chief Plant Licensing Branch 1-2 Division of Operating Reactor licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance: March 19, 2013

ATTACHMENT TO LICENSE AMENDMENT NO. 170 FACILITY OPERATING LICENSE NO. NPF-85 DOCKET NO. 50-353 Replace the following page of the Facility Operating License with the revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.

Remove Page 3 Page 3 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 xv xv 3/48-27 3/48-27

- 3 (4)

Pursuant to the Act and 10 CFR Parts 30, 40, 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)

Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility, and to receive and possess, but not separate, such source, byproduct, and special nuclear materials as contained in the fuel assemblies and fuel channels from the Shoreham Nuclear Power Station.

C.

This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I (except as exempted from compliance in Section 2.0. below) and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level Exelon Generation Company is authorized to operate the facility at reactor core power levels of 3515 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2)

Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 170, are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3)

Fire Protection (Section 9.5, SSER-2, -4)*

Exelon Generation Company shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report for the facility, and as approved in the NRC Safety Evaluation Report dated August 1983 through Supplement 9, dated August 1989, and Safety Evaluation dated November 20,1995, subject to the following provision:

The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

• The parenthetical notation following the title of license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Amendment No.4, 2:+, 54, )g, 92, 00, ~, 170

ELECTRICAL POWER SYSTEMS (Continued)

Table 4.8.2.1-1 Ba Surveillance Requirements....................... 3/4 8-13 D.C. Sources - Shutdown.................................... 3/4 8 14 3/4.8.3 ONSITE POWER DISTRIBUTION SYSTEMS Distribution rating................................... 3/4 8-15 Di stri buti on - Shutdown.................................... 3/4 8-18 3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES (Deleted).................................................. 3/4 8 21 (Deleted).................................................. 3/4 8-27 Reactor Protection System Electric Power Monitoring........ 3/4 8-28 3/4.9.1 REACTOR MODE SWITCH........................................ 3/4 9-1 3/4.9.2 HjSTRUMENTATION................,........................... 3/4 9 3 3/4.9.3 CONTROL ROD POSITION....................................... 3/4 9-5 3/4.9.4 DECAY T ME................................................ 3/496 3/4.9.5 COMMUNICATIONS............................................. 3/4 9 7 3/4.9.6 REFUELING PL.ATFORM......................................... 3/4 9-8 3/4.9.7 CRANE TRAVEL - SPENT FUEL STORAGE POOL..................... 3/4 9 10 3/4.9.8 WATER LEVEL - REACTOR VESSEL.............,........... ".... 3/4 9 11 3/4.9.9 WATER LEVEL SPENT FU L STORAGE POOL...................... 3/4 9 12 LIMERICK UNIT 2 xv Amendment No. ~. 170

PAGE INTENTIONALLY LEFT BLANK LIMERICK UNIT 2 3/4 8-27 Amendment No. J4, +4+, 170

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 209 AND 170 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 November 14, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML123200446), Exelon Generation Company, LLC (Exelon, the licensee), requested changes to the Technical Specifications (TSs) for Limerick Generating Station (LGS), Units 1 and 2. The proposed amendments would relocate the Technical Specification (TS) requirements for motor-operated valve (MOV) thermal overload protection from the LGS TSs to the LGS Technical Requirements Manual (TRM). The TRM is a licensee controlled document. Specifically, Limiting Condition for Operation (LCO) 3.8.4.2, "Motor Operated Valves Thermal Overload Protection," and its associated Surveillance Requirements (SRs) 4.8.4.2.1 and 4.8.4.2.2 would be relocated to the TRM. TS Index page xv would also be revised to reflect that the MOV thermal overload protection TS has been deleted.

2.0 REGULATORY EVALUATION

2.1 Regulatory Discussion The Nuclear Regulatory Commission's (NRC's or the Commission's) regulatory requirements related to the content of the TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, "Technical specifications." This regulation requires that the TSs include items in the following five specific categories: (1) safety limits, limiting safety system settings, and limiting control settings, (2) LCOs, (3) SRs, (4) design features, and (5) administrative controls. The regulation does not specify the particular reqUirements to be included in a plant's TSs.

On July 22, 1993 (58 FR 39132), the Commission published a "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (FInal Policy Statement),

which discussed the criteria to determine the items that are required to be included in the TSs as LCOs. The criteria were subsequently incorporated into the regulations by an amendment to 10 CFR 50.36 (60 FR 36953, July 19, 1995). Specifically, 10 CFR 50.36(c)(2)(ii) requires that a TS LCO be established for each item meeting one or more of the following criteria:

- 2 Criterion 1 Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 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.

Criterion 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.

Criterion 4 A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

As discussed in the Federal Register notice for the final rule dated July 19, 1995 (60 FR 36955):

LCOs that do not meet any of the criteria, and their associated actions and surveillance requirements, may be proposed for relocation from the technical specifications to licensee-controlled documents, such as the FSAR [Final Safety Analysis Report]. The criteria may be applied to either standard or custom technical specifications.

As discussed in the licensee's application dated November 14, 2012, the proposed amendment would relocate the MOV thermal overload protection TS requirements to the TRM, which is a licensee-controlled document.

Nuclear Energy Institute (NEI) guidance document NEI 98-03, Revision 1, "Guidelines for Updating Final Safety Analysis Reports" (ADAMS Accession No. ML003779028) lists the following methods of controlling the TRM on page 7 of Appendix A:

The TRM or other licensee controlled document is explicitly "incorporated by reference" into the UFSAR [Updated Final Safety Analysis Report]. Under this approach, the referenced document is subject to the change control requirements of 10 CFR 50.59 and the update/reporting requirements of 10 CFR 50.71 (e), e.g., periodic submittal of change pages, etc.

The TRIVI or other licensee controlled document is treated in a manner consistent with procedures fully or partially described in the UFSAR. Under this approach, the referenced document is maintained on-site in accordance with licensee administrative processes, and changes are evaluated using 10 CFR 50.59.

- 3 Regulatory Guide (RG) 1.181, "Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50.71(e)," dated September 1999 (ADAMS Accession No. ML992930009), states that Revision 1 of NEI 98-03 provides methods that are acceptable to the NRC staff for complying with the provisions of 10 CFR 50.71(e).

The LGS TRM is described in Section 13.5, "Plant Procedures," of the LGS UFSAR.

Specifically, UFSAR Section 13.5.3, "Operations Technical Requirements Manual (TRM),"

states, in part, that "the TRM is treated in a manner consistent with procedures fully or partially described in the UFSAR, and therefore, is controlled as a procedure in accordance with the applicable established procedure process." This section of the UFSAR and the licensee's application dated November 14, 2012, state that future changes to the relocated TS reqUirements contained in the TRM are subject to the requirements in 10 CFR 50.59.

2.2 Current TS Requirements and Equipment Description LCO 3.8.4.2 requires that the thermal overload protection for all Class 1 E MOVs either be:

(1) continuously bypassed for all valves with maintained position control switches, or (2) bypassed only under accident conditions for all valves with spring return to normal control switches. This LCO is applicable whenever the associated MOVs are required to be operable.

The TS Action statement requires that, when the LCO requirements are not met for one or more of the applicable MOVs, the thermal overload bypass shall be restored within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or the affected valves must be declared inoperable and the appropriate Action statements for the affected systems must be applied.

As discussed in RG 1.106, Revision 2, "Thermal Overload Protection for Electric Motors on Motor-Operated Valves," dated February 2012 (ADAMS Accession No. ML112580358):

Typical valve actuator motors are intermittent-duty, high-torque motors. When an actuator motor receives a signal to operate, the motor must attain operating speed quickly with sufficient force to deliver the equivalent of a hammer blow to the valves stem to initiate movement. If a valve is tightly sealed or must operate under a high differential pressure or flow condition, the initial period of operation when opening the valve calls for a high torque at low speed demand on the motor. During the period of time when the valve is unseating or initially opening, the motor may draw high current. Starting current (which is usually assumed to be equivalent to locked-rotor current) drawn by a motor may be 4 to 10 times higher than the motor's continuous current rating. A similar condition may exist when a valve begins its closing stroke because of interaction with the backseat.

During closing stroke, the motor experiences a relatively high-speed/low-torque condition until the disc begins to interact with fluid flow. Thereafter, a low speed/high-torque motor operating condition can occur during the last half of the valve stroke and as the valve disc is being seated.

Both high-torque/low speed and low-torque/high speed conditions generate heat that, if excessive, can cause deterioration of the insulation in the motor winding.

If the heat buildup is severe, it can cause burnout of the winding insulation in a matter of seconds. Damage to the rotor also may occur. Moreover, degradation

- 4 of the winding insulation and the rotor may occur in small increments and then fail under some particular demand depending on the degree and recurrence of the heat buildup. Thermal overload protection devices can be used to protect against such deficiencies by cutting off power to the motor to avoid degradation of the winding insulation and the rotor.

Since thermal overload protection devices cut off power to the valve motor, there is a potential that valve travel could be stopped before the desired position of the valve is reached. As discussed in the licensee's application dated November 14,2012, bypassing the thermal overload protection, of certain MOVs, minimizes the potential that the actuation of a thermal overload device could prevent the MOV from performing its intended function during a design basis accident. As discussed in the application and in UFSAR Section 8.1.6.1.19, the only time that the thermal overload protection would actually stop valve travel would be for manual operation of an MOV with a spring return to normal control switch.

3.0 TECHNICAL EVALUATION

The licensee's application dated November 14,2012, stated that the proposed relocation of the MOV thermal overload protection TS to the TRM is justified because the associated LCO does not meet any of the criteria in 10 CFR 50.36(c)(2)(ii). The NRC staff evaluated the proposed relocation of the LGS TS requirements against the criteria of 10 CFR 50.36(c)(2)(ii) as discussed below in Safety Evaluation (SE) Sections 3.1 through 3.4.

3.1 Evaluation of Proposed TS Relocation against Criterion 1 Criterion 1 of 10 CFR 50.36(c)(2)(ii) applies to:

Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

The function of the MOV thermal overload protection devices and the bypassing of the thermal overload protection, associated with LCO 3.8.4.2, is described above in SE Section 2.2. These devices and the bypassing of the devices is not instrumentation used to detect degradation of the reactor coolant boundary. Therefore, the NRC staff concludes that LCO 3.8.4.2 does not meet Criterion 1.

3.2 Evaluation of Proposed TS Relocation against Criterion 2 Criterion 2 of 10 CFR 50.36(c)(2)(ii) applies to:

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.

The MOV thermal overload protection devices and the bypassing of the thermal overload protection, associated with LCO 3.8.4.2, are not process variables. The MOV thermal overload protection devices are design features, however, these design features are provided to protect

- 5 the valve motor. They are not an initial condition of a design-basis accident or a transient analysis described in the UFSAR.

The bypassing of the MOV thermal overload devices, as described in lCO 3.8.4.2, is an operating restriction. However, based on an NRC staff review of lGS UFSAR Chapter 15, "Accident Analyses," the bypassing of the MOV thermal overload protection devices is not credited in the accident and transient analyses. Therefore, the operating restrictions in lCO 3.8.4.2 are not an initial condition of a design-basis accident or transient analysis.

Based on the above, the NRC staff concludes that lCO 3.8.4.2 does not meet Criterion 2.

3.3 Evaluation of Proposed TS Relocation against Criterion 3 Criterion 3 of 10 CFR 50.36(c)(2)(ii) applies to:

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.

The MOV thermal overload protection devices are components provided to protect the valve motor. However, based on an NRC staff review of lGS UFSAR Chapter 15, "Accident Analyses," these components are not credited to function or actuate in order to mitigate a design-basis accident or transient.

Based on a review of the design description provided in the licensee's application, and a similar discussion provided in lGS UFSAR Section 8.1.6.1.19, the only time that the thermal overload device would actually stop MOV travel would be for manual operation of a MOV that uses a spring return to normal control switch. The thermal overload could then be bypassed, and MOV travel resumed, by holding the control switch in the "open or "close" position as necessary.

However, based on an NRC staff review of lGS UFSAR Chapter 15, "Accident Analyses," the bypassing of the thermal overload devices is not credited in the accident and transient analyses.

Based on the above, the NRC staff concludes that lCO 3.8.4.2 does not meet Criterion 3.

3.4 Evaluation of Proposed TS Relocation against Criterion 4 Criterion 4 of 10 CFR 50.36(c)(2)(ii) applies to:

A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The licensee's application dated November 14, 2012, stated that:

The bypassing of MOV TOl protection during accident conditions is not a structure, system, or component that operating experience or probabilistic risk assessment has shown to be significant to public health and safety. The

- 6 Maintenance Rule (10 CFR 50.65) does not require this to be monitored for unavailability separate from the associated MOV; therefore, unavailability monitoring of the MOV TOl protection bypass is not performed at lGS. In addition, a review of industry operating experience did not produce any examples where the failure of MOV TOl protection bypass has had a significant adverse effect on public health and safety. MOV TOl protection devices and their bypass are not specifically modeled in the lGS probabilistic risk assessment. MOV TOl protection bypass failure is an insignificant contributor to the total failure probability for the associated MOV. Thus, MOV TOl protection bypass during accident conditions does not meet Criterion 4.

The NRC staff finds the justification provided by the licensee, as discussed above, to be reasonable and consistent with 10 CFR 50.65 and the staff's knowledge. Therefore, the NRC staff concludes that lCO 3.8.4.2 does not meet Criterion 4.

3.5 Technical Evaluation Conclusion

As discussed in SE Section 2.1, consistent with the Federal Register notice for the final rule dated July 19, 1995 (60 FR 36955), "lCOs that do not meet any of the criteria, and their associated actions and surveillance requirements, may be proposed for relocation from the technical specifications to licensee-controlled documents."

Based on the evaluation in SE Sections 3.1 through 3.4, the NRC staff concludes that lCO 3.8.4.2 does not meet the criteria in 10 CFR 50.36(c)(2)(ii) requiring inclusion in the TSs.

The proposed amendment would also relocate SRs 4.8.4.2.1 and 4.8.4.2.2 to the TRM. As stated in 10 CFR 50.36(c)(3), U[s]urveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The only purpose of SRs 4.8.4.2.1 and 4.8.4.2.2 is to provide the test requirements to ensure that the requirements in lCO 3.8.4.2 are met. Since the lCO will be relocated to the TRM, the NRC staff concludes that the SRs would no longer be required to be included in the TSs, consistent with the requirements in 10 CFR 50.36(c)(3).

The licensee's application dated November 14, 2012, also stated the proposed relocation is consistent with NUREG-1433, "Standard Technical Specifications - General Electric BWR/4 Plants," Revision 4, dated April 2012, because the Standard TSs do not contain TS requirements for MOV thermal overload protection. The NRC staff agrees that the requirements proposed for relocation from the lGS TSs to the TRM are not among the requirements included in NUREG-1433.

As discussed in SE Section 1.0, the licensee proposes to relocate lCO 3.8.4.2 and SRs 4.8.4.2.1 and 4.8.4.2.2 to the lGS TRM. As noted above in SE Section 2.1, in accordance with the description provided in UFSAR Section 13.5.3, future changes to relocated TS requirements will be subject to the provisions of 10 CFR 50.59. The objectives of 10 CFR 50.59 are to ensure that licensees evaluate proposed changes to their facilities for their effects on the licensing basis of the plant, as described in the UFSAR, and to obtain prior NRC approval for changes that meet specified criteria as having a potential impact upon the basis for issuance of

- 7 the operating license. As such, the NRC staff concludes that there is reasonable assurance that future changes to the relocated requirements will be made in a manner that continues to protect public health and safety.

Based on the above evaluation, the NRC staff concludes that relocation of LCO 3.8.4.2 and SRs 4.8.4.2.1 and 4.8.4.2.2 to the LGS TRM is acceptable. The licensee has also proposed to revise TS index page iv to reflect that the MOV thermal overload protection requirements have been deleted from the TSs. This change is consistent with the proposed deletion and, therefore, is acceptable.

The licensee's application dated November 14,2012, provided revised TS Bases pages to be implemented with the associated TS changes. These pages were provided for information only and will be revised in accordance with the LGS TS Bases Control Program.

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 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 changes SRs.

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 (78 FR 1270). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR S1.22(c)(9). Pursuant to 10 CFR S1.22(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) there is reasonable assurance that 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: R. Ennis Date: March 19, 2013

March 19, 2013 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 SUB~IECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 -ISSUANCE OF AMENDMENTS RE: RELOCATION OF TECHNICAL SPECIFICATIONS FOR MOTOR-OPERATED VALVE THERMAL OVERLOAD PROTECTION (TAC NOS. ME9939 AND ME9940)

Dear Mr. Pacilio:

The Commission has issued the enclosed Amendment Nos. 209 and 170 to Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station, Units 1 and 2, respectively.

These amendments consist of changes to the Technical Specifications and Facility Operating Licenses in response to your application dated November 14, 2012.

The amendments relocate the Technical Specification (TS) requirements for motor-operated valve thermal overload protection from the TSs to the Technical Requirements Manual.

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

Sincerely, Ira!

Richard B. Ennis, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 209 to License No. NPF-39

2. Amendment No. 170 to License No. NPF-85

3. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

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