Text

Issuance of Amendments Adoption of Technical Specification Task Force (TSTF) Traveler TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation
	ML15083A403
Person / Time
Site:	Limerick
Issue date:	05/11/2015
From:	Richard Ennis; Plant Licensing Branch 1
To:	Bryan Hanson; Exelon Nuclear
	Ennis R, NRR/DORL/LPLI-2, 415-1420
References
	GL-08-001, TAC MF4412, TAC MF4413
	Download: ML15083A403 (32)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 WASHINGTON, D.C. 20555-0001 May 11, 2015

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1AND2 - ISSUANCE OF AMENDMENTS RE: ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE (TSTF) TRAVELER TSTF-523, "GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION" (TAC NOS. MF4412 AND MF4413)

Dear Mr. Hanson:

The Commission has issued the enclosed Amendment Nos. 216 and 178 to Renewed 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 (TSs) and Facility Operating Licenses in response to your application dated July 10, 2014.

The amendments revise and add Technical Specification (TS) surveillance requirements to address the concerns discussed in Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," dated January 11, 2008. The TS changes are based on TS Task Force (TSTF) Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," dated February 21, 2013.

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

Docket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 216 to Renewed NPF-39

2. Amendment No. 178 to Renewed NPF-85

3. Safety Evaluation cc w/encls: Distribution via Listserv Sincerely, Richard B. Ennis, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

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. 216 Renewed 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 July 10, 2014, 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 1 O 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 1 O 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 Renewed 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. 216, are hereby incorporated into this renewed 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 120 days.

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: May 11, 2015 FOR THE NUCLEAR REGULATORY COMMISSION Douglas A. Broaddus, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ATTACHMENT TO LICENSE AMENDMENT NO. 216 RENEWED FACILITY OPERATING LICENSE NO. NPF-39 DOCKET NO. 50-352 Replace the following page of the Renewed 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 Insert 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 3/4 4-25 3/4 4-26 3/4 5-4 3/4 6-15 3/4 6-16 3/4 7-9 3/4 9-17 3/4 9-18 Insert 3/4 4-25 3/4 4-26 3/4 5-4 3/4 6-15 3/4 6-16 3/4 7-9 3/4 9-17 3/4 9-18 (2)

Pursuant to the Act and 1 O CFR Part 70, to receive, possess and to use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (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 renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 1 O CFR Chapter I (except as exempted from compliance in Section 2.D. 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 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 renewed license shall be completed as specified. Attachment 1 is hereby incorporated into this renewed license.

(2)

Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 216, are hereby incorporated into this renewed license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Renewed License No. NPF-39 Amendment No. 216

REACTOR COOLANT SYSTEM 3/4.4.9 RESIDUAL HEAT REMOVAL HOT SHUTDOWN LIMITING CONDITION FOR OPERATION 3.4.9.1 Two (2) independent RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one (1) RHR shutdown cooling subsystem shall be in operation. * ** ***

Each independent RHR shutdown cooling subsystem shall consist of at least:

a.

One OPERABLE RHR pump, and

b.

One OPERABLE RHR heat exchanger, not common to the two (2) independent subsystems.

APPLICABILITY:

OPERATIONAL CONDITION 3, with reactor vessel pressure less than the RHR cut-in permissive setpoint.

ACTION:

a.

With less than the above required independent RHR shutdown cooling subsystems OPERABLE, immediately initiate corrective action to return the required independent subsystems to OPERABLE status as soon as possible.

Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify the availability of at least one alternate method capable of decay heat removal for each inoperable independent RHR shutdown cooling subsystem.

Be in at least COLD SHUTDOWN within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .****

b.

With no independent RHR shutdown cooling subsystem in operation, immediately initiate corrective action to return at least one (1) independent subsystem to operation as soon as possible.

Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months establish reactor coolant circulation by an alternate method and monitor reactor coolant temperature and pressure at least once per hour.

SURVEILLANCE REQUIREMENTS 4.4.9.1.1 At least one independent RHR shutdown cooling subsystem or alternate method shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.4.9.1.2 Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.*****

One independent RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other independent subsystem is OPERABLE and in operation.

- The shutdown cooling pump may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8-hour period provided the other independent subsystem is OPERABLE.

- - The independent RHR shutdown cooling subsystem may be removed from operation during hydrostatic testing.

- - - Whenever two or more RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

- - - - Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is less I than the RHR cut-in permissive setpoint.

LIMERICK - UNIT 1 3/4 4-25 Amendment No.

-9+,-+/--+/-9,~. 216

REACTOR COOLANT SYSTEM COLD SHUTDOWN LIMITING CONDITION FOR OPERATION 3.4.9.2 Two (2) RHR shutdown cooling subsystems shall be OPERABLE, and with no recirculation pump in operation, at least one (1) RHR shutdown cooling subsystem shall be in operation. * ** ***

APPLICABILITY:

OPERATIONAL CONDITION 4.

ACTION: #

a.

With one (1) or two (2) RHR shutdown cooling subsystems inoperable:

1.

Within one (1) hour, and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.

b.

With no RHR shutdown cooling subsystems in operation and no recirculation pump in operation:

1.

Within one (1) hour from discovery of no reactor coolant circulation, and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, verify reactor coolant circulating by an alternate method; and

2.

Once per hour monitor reactor coolant temperature and pressure.

SURVEILLANCE REQUIREMENTS 4.4.9.2.l At least one (1) RHR shutdown cooling subsystem or recirculation pump is operating or an alternate method shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.4.9.2.2 Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up two (2) hours per eight (8) hour period.

One (1) RHR shutdown cooling subsystem may be inoperable for up to two (2) hours for the performance of Surveillances.

The shutdown cooling subsystem may be removed from operation during hydrostatic testing.

Separate Action entry is allowed for each shutdown cooling subsystem.

LIMERICK - UNIT 1 3/4 4-26 Amendment No. f.,-+/--+/--9-.~. 216

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.l The emergency core cooling systems shall be demonstrated OPERABLE by:

a.

In accordance with the Surveillance Frequency Control Program:

1.

For the CSS, the LPCI system, and the HPCI system:

a)

Verifying locations susceptible to gas accumulation are sufficiently filled with water.

b)

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct*

position.***

2.

For the LPCI system, verifying that both LPCI system subsystem cross-tie valves CHV-51-182 A, B) are closed with power removed from the valve operators.

3.

For the HPCI system, verifying that the HPCI pump flow controller is in the correct position.

4.

For the CSS and LPCI system, performance of a CHANNEL FUNCTIONAL TEST of the injection header ~P instrumentation.

b.

Verifying that, when tested pursuant to Specification 4.0.5:

1.

Each CSS pump in each subsystem develops a flow of at least 3175 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of ~ 105 psid plus head and line losses.

2.

Each LPCI pump in each subsystem develops a flow of at least 10,000 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of

~ 20 psid plus head and line losses.

3.

The HPCI pump develops a flow of at least 5600 gpm against a test line pressure which corresponds to a reactor vessel pressure of 1040 psig plus head and line losses when steam is being supplied to the turbine at 1040, +13, -120 psig.**

c.

In accordance with the Surveillance Frequency Control Program:

1.

For the CSS, the LPCI system, and the HPCI system, performing a system functional test which includes simulated automatic actuation of the system throughout its emergency operating sequence and verifying that each automatic valve in the flow path actuates to its correct position.

Actual injection of coolant into the reactor vessel may be excluded from this test.

Except that an automatic valve capable of automatic return to its ECCS position when an ECCS signal is present may be in position for another mode of operation.

The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test.

If OPERABILITY is not successfully demonstrated within the 12-hour period, reduce reactor steam dome pressure to less than 200 psig within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Not required to be met for system vent flow paths opened under administrative control.

LIMERICK - UNIT 1 3/4 5-4 Amendment No..&9,++/-.~.~. 216

CONTAINMENT SYSTEMS SUPPRESSION POOL SPRAY LIMITING CONDITION FOR OPERATION 3.6.2.2 The suppression pool spray mode of the residual heat removal (RHR) system shall be OPERABLE with two independent loops, each loop consisting of:

a.

b.

One OPERABLE RHR pump, and An OPERABLE flow path capable of recirculating water from the suppression chamber through an RHR heat exchanger and the suppression pool spray sparger(s).

APPLICABILITY:

OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

a.

With one suppression pool spray loop inoperable, restore the inoperable loop to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

With both suppression pool spray loops inoperable, restore at least one loop to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN* within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SURVEILLANCE REQUIREMENTS 4.6.2.2 The suppression pool spray mode of the RHR system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.

By verifying that each of the required RHR pumps develops a flow of at least 500 gpm on recirculation flow through the RHR heat exchanger and the suppression pool spray sparger when tested pursuant to Speci-fication 4.0.5.

c.

By verifying RHR suppression pool spray subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

Whenever both RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

LIMERICK - UNIT 1 3/4 6-15 Amendment No. ~..J-J.+/-..~, 216

CONTAINMENT SYSTEMS SUPPRESSION POOL COOLING LIMITING CONDITION FOR OPERATION 3.6.2.3 The suppression pool cooling mode of the residual heat removal (RHR) system shall be OPERABLE with two independent loops, each loop consisting of:

a.

One OPERABLE RHR pump, and

b.

An OPERABLE flow path capable of recirculating water from the suppression chamber through an RHR heat exchanger.

APPLICABILITY:

OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

a.

With one suppression pool cooling loop inoperable, restore the inoperable loop to OPERABLE status within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s** or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

With both suppression pool cooling loops inoperable, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN* within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SURVEILLANCE REQUIREMENTS 4.6.2.3 The suppression pool cooling mode of the RHR system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.

By verifying that each of the required RHR pumps develops a flow of at least 10,000 gpm on recirculation flow through the flow path including the RHR heat exchanger and its associated closed bypass valve, the suppression pool and the full flow test line when tested pursuant to Specification 4.0.5.

c.

By verifying RHR suppression pool cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

Whenever both RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

- During the extended 7-day Allowed Outage Time (AOT) specified by TS LCO 3.7.1.1, Action a.3.a) or a.3.b) to allow for RHRSW subsystem piping repairs, the 72-hour AOT for one inoperable suppression pool cooling loop may also be extended to 7 days for the same 7-day period.

LIMERICK - UNIT 1 3/4 6-16 Amendment No..e+,~,ge.J..J+,+ge,~,216

PLANT SYSTEMS 3/4.7.3 REACTOR CORE ISOLATION COOLING SYSTEM LIMITING CONDITION FOR OPERATION 3.7.3 The reactor core isolation cooling (RCIC) system shall be OPERABLE with an OPERABLE flow path capable of automatically taking suction from the suppression pool and transferring the water to the reactor pressure vessel.

APPLICABILITY:

OPERATIONAL CONDITIONS 1, 2, and 3 with reactor steam dome pressure greater than 150 psig.

ACTION:

a.

With the RCIC system inoperable, operation may continue provided the HPCI system is OPERABLE; restore the RCIC system to OPERABLE status within 14 days.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reduce reactor steam dome pressure to less than or equal to 150 psig within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

DELETED

c.

Specification 3.0.4.b is not applicable to RCIC.

SURVEILLANCE REQUIREMENTS 4.7.3 The RCIC system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by:

1.

Verifying locations susceptible to gas accumulation are sufficiently filled with water.

2.

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.**

3.

Verifying that the pump flow controller is in the correct position.

b.

In accordance with the Surveillance Frequency Control Program by verifying that the RCIC pump develops a flow of greater than or equal to 600 gpm in the test flow path with a system head corresponding to reactor vessel operating pressure when steam is being supplied to the turbine at 1040 + 13, - 120 psig.*

The prov1s1ons of Specification 4.0.4 are not applicable, provided the surveillance is performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test.

If OPERABILITY is not successfully demonstrated within the 12-hour period, reduce reactor steam pressure to less than 150 psig within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Not required to be met for system vent flow paths opened under administrative control.

LIMERICK - UNIT 1 3/4 7-9 Amendment No.

-&9,-+/--Ge,-+/-6-9,~.-&+/--+/-. 216

REFUELING OPERATIONS 3/4.9.11 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.11.1 One (1) RHR shutdown cooling subsystem shall be OPERABLE and in operation.

APPLICABILITY:

OPERATIONAL CONDITION 5, when irradiated fuel is in the reactor vessel and the water level is greater than or equal to 22 feet above the top of the reactor pressure vessel flange.

ACTION:

a.

With the required RHR shutdown cooling subsystem inoperable:

1.

Within one (1) hour, and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify an alternate method of decay heat removal is available.

b.

With the required action and associated completion time of Action "a" above not met.

1.

Immediately suspend loading of irradiated fuel assemblies into the reactor pressure vessel; and

2.

Immediately initiate action to restore REFUELING FLOOR SECONDARY CONTAINMENT INTEGRITY to OPERABLE status; and

3.

Immediately initiate action to restore one (1) Standby Gas Treatment subsystem to OPERABLE status; and

4.

Immediately initiate action to restore isolation capability in each required Refueling Floor secondary containment penetration flow path not isolated.

c.

With no RHR shutdown cooling subsystem in operation:

1.

Within one (1) hour from discovery of no reactor coolant circulation, and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, verify reactor coolant circulation by an alternate method; and

2.

Once per hour monitor reactor coolant temperature.

SURVEILLANCE REQUIREMENTS 4.9.11.1.l At least one (1) RHR shutdown cooling subsystem, or an alternate method, shall be verified to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.9.11.1.2 Verify required RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

The required RHR shutdown cooling subsystem may be removed from operation for up to two (2) hours per eight (8) hour period.

LIMERICK - UNIT 1 3/4 9-17 Amendment No. f.,++/--g,~,216

REFUELING OPERATIONS LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.11.2 Two (2) RHR shutdown cooling subsystems shall be OPERABLE, and one (1)

RHR shutdown cooling subsystem shall be in operation.

APPLICABILITY:

OPERATIONAL CONDITION 5, when irradiated fuel is in the reactor vessel and the water level is less than 22 feet above the top of the reactor pressure vessel flange.

ACTION:

a.

With one ( 1) or two ( 2) required RHR shutdown cooling subsystems inoperable:

1.

Within one (1) hour, and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify an alternate method of decay heat removal is available for each inoperable required RHR shutdown cooling subsystem.

b.

With the required action and associated completion time of Action "a" above not met:

1.

Immediately initiate action to restore REFUELING FLOOR SECONDARY CONTAINMENT INTEGRITY to OPERABLE status; and

2.

Immediately initiate action to restore one (1) Standby Gas Treatment subsystem to OPERABLE status; and

3.

Immediately initiate action to restore isolation capability in each required Refueling Floor secondary containment penetration flow path not isolated.

c.

With no RHR shutdown cooling subsystem in operation:

1.

Within one (1) hour from discovery of no reactor coolant circulation, and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, verify reactor coolant circulation by an alternate method; and

2.

Once per hour monitor reactor coolant temperature.

SURVEILLANCE REQUIREMENTS 4.9.11.2.1 At least one (1) RHR shutdown cooling subsystem, or an alternate method, shall be verified to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.9.11.2.2 Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

The required operating shutdown cooling subsystem may be removed from operation for up to two (2) hours per eight (8) hour period.

LIMERICK - UNIT 1 314 9-18 Amendment No.

-9+,-+/--+/--9,~,216

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. 178 Renewed 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 July 10, 2014, 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 1 O 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 Renewed 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. 178, are hereby incorporated into this renewed 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 120 days.

FOR THE NUCLEAR REGULATORY COMMISSION

~1t/:4~L

Attachment:

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

May 11, 2015 Douglas A. Broaddus, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ATTACHMENT TO LICENSE AMENDMENT NO. 178 RENEWED FACILITY OPERATING LICENSE NO. NPF-85 DOCKET NO. 50-353 Replace the following page of the Renewed 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 Insert 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 3/4 4-25 3/4 4-26 3/4 5-4 3/4 6-15 3/4 6-16 3/4 7-9 3/4 9-17 3/4 9-18 Insert 3/4 4-25 3/4 4-26 3/4 5-4 3/4 6-15 3/4 6-16 3/4 7-9 3/4 9-17 3/4 9-18 (2)

Pursuant to the Act and 10 CFR Part 70, to receive, possess and to use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (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 1 O 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 renewed 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.D. 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 8, as revised through Amendment No. 178, are hereby incorporated into this renewed license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Renewed License No. NPF-85 Amendment No. 178

REACTOR COOLANT SYSTEM 3/4.4.9 RESIDUAL HEAT REMOVAL HOT SHUTDOWN LIMITING CONDITION FOR OPERATION 3.4.9.1 Two (2) independent RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one (1) RHR shutdown cooling subsystem shall be in operation. * ** ***

Each independent RHR shutdown cooling subsystem shall consist of at least:

a.

One OPERABLE RHR pump, and

b.

One OPERABLE RHR heat exchanger, not common to the two (2) independent subsystems.

APPLICABILITY:

OPERATIONAL CONDITION 3, with reactor vessel pressure less than the RHR cut-in permissive setpoint.

ACTION:

a.

With less than the above required independent RHR shutdown cooling subsystems OPERABLE, immediately initiate corrective action to return the required independent subsystems to OPERABLE status as soon as possible.

Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify the availability of at least one alternate method capable of decay heat removal for each inoperable independent RHR shutdown cooling subsystem.

Be in at least COLD SHUTDOWN within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .****

b.

With no independent RHR shutdown cooling subsystem in operation, immediately initiate corrective action to return at least one (1) independent subsystem to operation as soon as possible.

Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months establish reactor coolant circulation by an alternate method and monitor reactor coolant temperature and pressure at least once per hour.

SURVEILLANCE REQUIREMENTS 4.4.9.1.1 At least one independent RHR shutdown cooling subsystem or alternate method shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.4.9.1.2 Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.*****

One independent RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other independent subsystem is OPERABLE and in operation.

- The shutdown cooling pump may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8-hour period provided the other independent subsystem is OPERABLE.

- - The independent RHR shutdown cooling subsystem may be removed from operation during hydrostatic testing.

- - - Whenever two or more RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

- - - - Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is less than the RHR cut-in permissive setpoint.

LIMERICK - UNIT 2 3/4 4-25 Amendment No. -M.~.M+. 178

REACTOR COOLANT SYSTEM COLD SHUTDOWN LIMITING CONDITION FOR OPERATION 3.4.9.2 Two (2) RHR shutdown cooling subsystems shall be OPERABLE, and with no recirculation pump in operation, at least one (1) RHR shutdown cooling subsystem shall be in operation. * ** ***

APPLICABILITY:

OPERATIONAL CONDITION 4.

ACTION: #

a.

With one (1) or two (2) RHR shutdown cooling subsystems inoperable:

1.

Within one (1) hour, and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem.

b.

With no RHR shutdown cooling subsystems in operation and no recirculation pump in operation:

1.

Within one (1) hour from discovery of no reactor coolant circulation, and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, verify reactor coolant circulating by an alternate method; and

2.

Once per hour monitor reactor coolant temperature and pressure.

SURVEILLANCE REQUIREMENTS 4.4.9.2.l At least one (1) RHR shutdown cooling subsystem or recirculation pump is operating or an alternate method shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.4.9.2.2 Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up two (2) hours per eight hour (8) period.

One (1) RHR shutdown cooling subsystem may be inoperable for up to two (2) hours for the performance of Surveillances.

The shutdown cooling subsystem may be removed from operation during hydrostatic testing.

Separate Action entry is allowed for each shutdown cooling subsystem.

LIMERICK - UNIT 2 3/4 4-26 Amendment No..e.i,gz,J.4-7., 178

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.1 The emergency core cooling systems shall be demonstrated OPERABLE by:

a.

In accordance with the Surveillance Frequency Control Program:

1.

For the CSS, the LPCI system, and the HPCI system:

a)

Verifying locations susceptible to gas accumulation are sufficiently filled with water.

b)

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct* position.***

2.

For the LPCI system, verifying that both LPCI system subsystem cross-tie valves (HV-51-282 A, B) are closed with power removed from the valve operators.

3.

For the HPCI system, verifying that the HPCI pump flow controller is in the correct position.

4.

For the CSS and LPCI system, performance of a CHANNEL FUNCTIONAL TEST of the injection header ~P instrumentation.

b.

Verifying that, when tested pursuant to Specification 4.0.5:

1.

Each CSS pump in each subsystem develops a flow of at least 3175 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of = 105 psid plus head and line losses.

2.

Each LPCI pump in each subsystem develops a flow of at least 10,000 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of

~ 20 psid plus head and line losses.

3.

The HPCI pump develops a flow of at least 5600 gpm against a test line pressure which corresponds to a reactor vessel pressure of 1040 psig plus head and line losses when steam is being supplied to the turbine at 1040, +13, -120 psig.**

c.

In accordance with the Surveillance Frequency Control Program:

1.

For the CSS, the LPCI system, and the HPCI system, performing a system functional test which includes simulated automatic actuation of the system throughout its emergency operating sequence and verifying that each automatic valve in the flow path actuates to its correct position.

Actual injection of coolant into the reactor vessel may be excluded from this test.

Except that an automatic valve capable of automatic return to its ECCS position when an ECCS signal is present may be in position for another mode of operation.

The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test.

If OPERABILITY is not successfully demonstrated within the 12-hour period, reduce reactor steam dome pressure to less than 200 psig within the following 72-hours.

Not required to be met for system vent flow paths opened under administrative control.

LIMERICK - UNIT 2 3/4 5-4 Amendment No..J-4,-5-+/-,-+/--4..f., 178

CONTAINMENT SYSTEMS SUPPRESSION POOL SPRAY LIMITING CONDITION FOR OPERATION 3.6.2.2 The suppression pool spray mode of the residual heat removal (RHR) system shall be OPERABLE with two independent loops, each loop consisting of:

a.

One OPERABLE RHR pump, and

b.

An OPERABLE flow path capable of recirculating water from the suppression chamber through an RHR heat exchanger and the suppression pool spray sparger(s).

APPLICABILITY:

OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

a.

With one suppression pool spray loop inoperable, restore the inoperable loop to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

With both suppression pool spray loops inoperable, restore at least one loop to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN* within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SURVEILLANCE REQUIREMENTS 4.6.2.2 The suppression pool spray mode of the RHR system shall be demonstrated OPERABLE:

a.

In accordance with the Survei 11 ance Frequency Control Program by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.

By verifying that each of the required RHR pumps develops a flow of at least 500 gpm on recirculation flow through the RHR heat exchanger and the suppression pool spray sparger when tested pursuant to Speci-fication 4.0.5.

c.

By verifying RHR suppression pool spray subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

Whenever both RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

LIMERICK - UNIT 2 3/4 6-15 Amendment No. J.G,.W,-9-Z,-+/-4+, 178

CONTAINMENT SYSTEMS SUPPRESSION POOL COOLING LIMITING CONDITION FOR OPERATION 3.6.2.3 The suppression pool cooling mode of the residual heat removal (RHR) system shall be OPERABLE with two independent loops, each loop consisting of:

a.

One OPERABLE RHR pump, and

b.

An OPERABLE flow path capable of recirculating water from the suppression chamber through an RHR heat exchanger.

APPLICABILITY:

OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

a.

With one suppression pool cooling loop inoperable, restore the inoperable loop to OPERABLE status within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s** or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and tn COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

With both suppression pool cooling loops inoperable, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN* within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SURVEILLANCE REQUIREMENTS 4.6.2.3 The suppression pool cooling mode of the RHR system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

b.

By verifying that each of the required RHR pumps develops a flow of at least 10,000 gpm on recirculation flow through the flow path including the RHR heat exchanger and its associated closed bypass valve, the suppression pool and the full flow test line when tested pursuant to Specification 4.0.5.

c.

By verifying RHR suppression pool cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

Whenever both RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

- During the extended 7-day Allowed Outage Time (AOT) specified by TS LCO 3.7.1.1, Action a.3.a) or a.3.b) to allow for RHRSW subsystem piping repairs, the 72-hour AOT for one inoperable suppression pool cooling loop may also be extended to 7 days for the same 7-day period.

LIMERICK - UNIT 2 314 6-16 Amendment No..J-0,+G,~,-+/-4+,~, 178

PLANT SYSTEMS 3/4.7.3 REACTOR CORE ISOLATION COOLING SYSTEM LIMITING CONDITION FOR OPERATION 3.7.3 The reactor core isolation cooling (RCIC) system shall be OPERABLE with an OPERABLE flow path capable of automatically taking suction from the suppression pool and transferring the water to the reactor pressure vessel.

APPLICABILITY:

OPERATIONAL CONDITIONS 1, 2, and 3 with reactor steam dome pressure greater than 150 psig.

ACTION:

a.

With the RCIC system inoperable, operation may continue provided the HPCI system is OPERABLE; restore the RCIC system to OPERABLE status within 14 days.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reduce reactor steam dome pressure to less than or equal to 150 psig within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

DELETED

c.

Specification 3.0.4.b is not applicable to RCIC.

SURVEILLANCE REQUIREMENTS 4.7.3 The RCIC system shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by:

1.

Verifying locations susceptible to gas accumulation are sufficiently filled with water.

2.

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.**

I

3.

Verifying that the pump flow controller is in the correct position.

b.

In accordance with the Surveillance Frequency Control Program by verifying that the RCIC pump develops a flow of greater than or equal to 600 gpm in the test flow path with a system head corresponding to reactor vessel operating pressure when steam is being supplied to the turbine at 1040 + 13, - 120 psig.*

The prov1s1ons of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure is adequate to perform the test.

If OPERABILITY is not successfully demonstrated within the 12-hour period, reduce reactor steam dome pressure to less than 150 psig within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Not required to be met for system vent flow paths opened under administrative control.

LIMERICK - UNIT 2 3/4 7-9 Amendment No.

&+/-,~,-l-4+,-1-7-J, 178

REFUELING OPERATIONS 3/4.9.11 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.11.1 One (1) RHR shutdown cooling subsystem shall be OPERABLE and in operation.

APPLICABILITY:

OPERATIONAL CONDITION 5, when irradiated fuel is in the reactor vessel and the water level is greater than or equal to 22 feet above the top of the reactor pressure vessel flange.

ACTION:

a.

With the required RHR shutdown cooling subsystem inoperable:

1.

Within one ( 1) hour, and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify an alternate method of decay heat removal is available.

b.

With the required action and associated completion time of Action "a" above not met.

1.

Immediately suspend loading of irradiated fuel assemblies into the reactor pressure vessel; and

2.

Immediately initiate action to restore REFUELING FLOOR SECONDARY CONTAINMENT INTEGRITY to OPERABLE status; and

3.

Immediately initiate action to restore one (1) Standby Gas Treatment subsystem to OPERABLE status; and

4.

Immediately initiate action to restore isolation capability in each required Refueling Floor secondary containment penetration flow path not isolated.

c.

With no RHR shutdown cooling subsystem in operation:

1.

Within one (1) hour from discovery of no reactor coolant circulation, and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, verify reactor coolant circulation by an alternate method; and

2.

Once per hour monitor reactor coolant temperature.

SURVEILLANCE REQUIREMENTS 4.9.11.1.l At least one (1) RHR shutdown cooling subsystem, or an alternate method, shall be verified to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.9.11.1.2 Verify required RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

The required RHR shutdown cooling subsystem may be removed from operation for up to two (2) hours per eight (8) hour period.

LIMERICK - UNIT 2 314 9-17 Amendment No.

-IH-,~.-+/--4-7-.178

REFUELING OPERATIONS LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.11.2 Two (2) RHR shutdown cooling subsystems shall be OPERABLE, and one (1)

RHR shutdown cooling subsystem shall be in operation.

APPLICABILITY:

OPERATIONAL CONDITION 5, when irradiated fuel is in the reactor vessel and the water level is less than 22 feet above the top of the reactor pressure vessel flange.

ACTION:

a.

With one (1) or two (2) required RHR shutdown cooling subsystems inoperable:

1.

Within one (1) hour, and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify an alternate method of decay heat removal is available for each inoperable required RHR shutdown cooling subsystem.

b.

With the required action and associated completion time of Action "a" above not met:

1.

Immediately initiate action to restore REFUELING FLOOR SECONDARY CONTAINMENT INTEGRITY to OPERABLE status; and

2.

Immediately initiate action to restore one (1) Standby Gas Treatment subsystem to OPERABLE status; and

3.

Immediately initiate action to restore isolation capability in each required Refueling Floor secondary containment penetration flow path not isolated.

c.

With no RHR shutdown cooling subsystem in operation:

1.

Within one (1) hour from discovery of no reactor coolant circulation, and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, verify reactor coolant circulation by an alternate method; and

2.

Once per hour monitor reactor coolant temperature.

SURVEILLANCE REQUIREMENTS 4.9.11.2.1 At least one (1) RHR shutdown cooling subsystem, or an alternate method, shall be verified to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.9.11.2.2 Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

The required operating shutdown cooling subsystem may be removed from operation for up to two (2) hours per eight (8) hour period.

LIMERICK - UNIT 2 3/4 9-18 Amendment No..e-+/-,gz,-+/--47-, 178

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 216 AND 178 TO RENEWED 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 July 10, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14191B180), Exelon Generation Company, LLC (Exelon, the licensee), requested changes to the Technical Specifications (TSs) for Limerick Generating Station (LGS), Units 1 and 2. Specifically, the licensee requested to adopt U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force {TSTF} Standard Technical Specifications {STS} Change Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," dated February 21, 2013 (ADAMS Accession No. ML13053A075).

The proposed change would revise Surveillance Requirements (SRs) related to gas accumulation for the emergency core cooling system (ECCS) and reactor core isolation cooling (RCIC) system. The proposed change would also add new SRs related to gas accumulation for the residual heat removal (RHR), suppression pool cooling, and suppression pool spray systems.

The licensee stated that the License Amendment Request (LAR) is consistent with NRC-approved Traveler TSTF-523. The availability of this TS improvement was announced in the Federal Register on January 15, 2014 (79 FR 2700), as part of the consolidated line item improvement process (CLllP).

2.0 REGULATORY EVALUATION

2.1 Background

Gas accumulation in reactor systems can result in water hammer, pump cavitation, and pumping of non-condensable gas into the reactor vessel. These effects may result in the subject system being unable to perform its specified safety function. The NRC issued Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," in January 2008, to address the issue of gas accumulation in ECCS, decay heat removal (OHR) systems, and containment spray (CS) systems (ADAMS Accession No. ML072910759). The industry and NRC staff agreed that a change to the STS and plant-specific TS would be necessary to address some issues discussed in GL 2008-01. TSTF-523 contains changes to the TS SRs and TS Bases to address some of the concerns in GL 2008-01. The licensee proposed amending the LGS Units 1 and 2 TSs using a plant-specific adoption of the TSTF-523 changes.

2.2 Technical Specification Changes Changes were proposed for SRs 4.4.9.1, 4.4.9.2, 4.5.1, 4.7.3.a.1, 4.7.3.a.2, 4.9.11.1 and 4.9.11.2, as well as the addition of new SRs 4.4.9.1.2, 4.4.9.2.2, 4.6.2.2.c, 4.6.2.3.c, 4.9.11.1.2 and 4.9.11.1.2.2 to TS 3/4.4.9.1, "Residual Heat Removal Hot Shutdown, TS 3/4.4.9.2, "Residual Heat Removal Cold Shutdown, TS 3/4.5.1, "ECCS - Operating, TS 3/4.6.2.2, "Suppression Pool Spray, TS 3/4.6.2.3, "Suppression Pool Cooling, TS 3/4.7.3, "Reactor Core Isolation Cooling System," and TS 3/4.9.11 "Residual Heat Removal and Coolant Circulation,"

respectively. Associated TS Bases changes were submitted for information only for the respective limiting conditions for operations (LCOs), SR changes, and SR additions.

2.3 Regulatory Review The regulations in Appendix A to Title 1 O of the Code of Federal Regulations (1 o CFR) Part 50 or similar plant-specific principal design criteria provide design requirements. Appendix B to 10 CFR Part 50, the TSs, and the licensee quality assurance programs provide operating requirements. The regulatory requirements of 10 CFR Part 50, Appendix A, that are applicable to gas management in the subject systems include: General Design Criteria (GDC) 1, 34, 35, 36, 37, 38, 39 and 40. GDC 1 requires that the subject systems be designed, fabricated, erected, and tested to quality standards. GDC 34 requires an RHR system be designed to maintain specified acceptable fuel design limits and to meet design conditions that are not exceeded if a single failure occurs and specified electrical power systems fail. GDC 35, 36, and 37 require an ECCS design that meets performance, inspection, and testing requirements.

Additionally, the regulations in 1 O CFR 50.46 provide specified ECCS performance criteria.

GDC 38, 39, and 40 require a containment heat removal system design that meets performance, inspection, and testing requirements.

Quality assurance criteria provided in 10 CFR Part 50, Appendix B, that apply to gas management in the subject systems include: Criteria Ill, V, XI, XVI, and XVII. Criteria Ill and V require measures to ensure that applicable regulatory requirements and the design basis, as defined in 1 O CFR 50.2, "Definitions, and as specified in the license application, are correctly translated into controlled specifications, drawings, procedures, and instructions. Criterion XI requires a test program to ensure that the subject systems will perform satisfactorily in service and requires that test results shall be documented and evaluated to ensure that test requirements have been satisfied. Criterion XVI requires measures to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances, are promptly identified and corrected, and that significant conditions adverse to quality are documented and reported to management.

Criterion XVII requires maintenance of records of activities affecting quality.

The NRC's regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36(c). The regulations at 1 O CFR 50.36 require that the TSs include items in the following categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls. SRs 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 LCOs will be met. Typically, TS Section 5 requires that licensees establish, implement, and maintain written procedures covering the applicable procedures recommended in Appendix A to Regulatory Guide (RG) 1.33, "Quality Assurance Program Requirements (Operation)." Appendix A to RG 1.33 identifies instructions for filling and venting the ECCS and OHR system, as well as for draining and refilling heat exchangers. Standard TSs and most licensee TSs include SRs to verify that at least some of the subject systems piping is filled with water.

The NRC's guidance for the format and content of licensee TSs can be found NUREG-1433, "Standard Technical Specifications General Electric Plants BWR/4."

Regulatory guidance for the NRC staff's review of containment heat removal systems, ECCS, and RHR systems is provided in the following revisions and sections of NUREG-0800, "Standard Review Plan (SRP) for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition:"

Revision 5 of SRP, Section 6.2.2, "Containment Heat Removal Systems," dated March 2007 (ADAMS Accession No. ML070160661 ), provides the procedures concerning the review of containment heat removal under post-accident conditions to help ensure compliance with GDC 38, 39, and 40.

Revision 3 of SRP, Section 6.3, "Emergency Core Cooling System," dated March 2007 (ADAMS Accession No. ML070550068), provides the procedures concerning the review of ECCS to help ensure compliance with GDC 35, 36, and 37.

Revision 5 of SRP, Section 5.4.7, "Residual Heat Removal (RHR) System," dated May 2010 (ADAMS Accession No. ML100680577), provides the procedures concerning the review of RHR system as it is used to cool the reactor coolant system during and following shutdown to help ensure compliance with GDC 34.

3.0 TECHNICAL EVALUATION

The NRC staff evaluated the licensee's proposed amendments against the applicable regulatory guidance in the STS, as modified by TSTF-523. The proposed amendments adopted the TS format and content, to the extent practicable, contained in the changes made to NUREG-1433, by TSTF-523. The NRC staff found that the proposed amendments are consistent with guidance in the STS, as modified by TSTF-523.

The NRC staff compared the proposed changes to the existing SRs, and considered the regulatory requirements of 1 O CFR 50.36. The licensee proposed the following TS changes:

(1)

Renumber SR 4.4.9.1 to SR 4.4.9.1.1 and add SR 4.4.9.1.2, which states: "Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program. *****"

The associated footnote which would be added would state: "***** Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is less than the RHR cut-in permissive setpoint."

(2)

Renumber SR 4.4.9.2 to SR 4.4.9.2.1 and add SR 4.4.9.2.2, which states: "Verify RHR Shutdown Cooling Subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program."

(3)

Revise the language for SR 4.5.1.a.1.a from: "Verifying by venting at the high point vents that the system piping from the pump discharge valve to the system isolation valve is filled with water." to "Verifying locations susceptible to gas accumulation are sufficiently filled with water."

(4)

Add the footnote designator"***" to the end of SR 4.5.1.a.1.b, and the associated footnote which states: "***Not required to be met for system vent flow paths opened under administrative control."

(5)

Add SR 4.6.2.2.c, which states: "By verifying RHR suppression pool spray subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program."

(6)

Add SR 4.6.2.3.c, which states: "By verifying RHR suppression pool cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program."

(7)

Revise the language for SR 4.7.3.a.1 from: "Verifying by venting at the high point vents that the system piping from the pump discharge valve to the system isolation valve is filled with water." to "Verifying locations susceptible to gas accumulation are sufficiently filled with water."

(8)

Add the footnote designator"**" to the end of SR 4.7.3.a.2 and the associated footnote which states: "**Not required to be met for system vent flow paths opened under administrative control."

(9)

Renumber SR 4.9.11.1 to SR 4.9.11.1.1 and add SR 4.9.11.1.2, which states: "Verify required RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program."

(10)

Renumber SR 4.9.11.2 to SR 4.9.11.2.1 and add SR 4.9.11.2.2, which states: "Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program."

(11)

Add and revise the affected TS SR Bases language to state the purpose of the SR, discuss methods of identifying locations susceptible to gas accumulation, discuss gas volume acceptance criteria, discuss methods for performing the SR, consistent with licensee actions and on-going programs related to GL 2008-01, and describe the SR frequency.

(12)

Add and revise TS LCO Bases language to describe what is required for Operability of the systems and reiterate the importance of gas management.

The new language for the SRs was developed using licensee responses to GL 2008-01 and the NRC discussion contained in Task Interface Agreement {TIA) 2008-03, "Emergency Core Cooling System (ECCS) Voiding Relative To Compliance With Surveillance Requirements (SRs) 3.5.1.1, 3.5.2.3, and 3.5.3.1" (ADAMS Accession No. ML082560209). Many of the GL 2008-01 responses stated that licensees identified system locations susceptible to gas accumulation. In the TIA, the NRC stated that the intent of the TS SRs, which state full of water," may be met if the licensee can establish, through an Operability Determination, that there is a reasonable expectation that the system in question will perform its specified safety function. Therefore, the phrase, "sufficiently filled with water" was recommended for the proposed TS changes. In the TSs, "sufficiently filled with water" is understood to mean "sufficiently filled with water to support Operability." The regulation at 10 CFR 50.36(c)(3) states that one of the purposes of the SR is to verify that the LCO is met. Therefore, the new SR language, "[By] Verify[ing] the [system name] locations susceptible to gas accumulation are sufficiently filled with water," is acceptable since this language will allow the licensee to make a conclusion as to whether or not a system is operable.

The language for the notes that state that the SR does not have to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam dome pressure is less than the RHR cut-in permissive setpoint is acceptable because the note provides a limited time to perform the Surveillance after entering the Applicability of the LCO; however, under the STS usage rules (STS Section 1.4), the requirement to manage gas accumulation is not affected. Licensees must have confidence that the SR can be met or the LCO must be declared not met.

A note is added to SRs that require verification that valves in the flow path are in the correct position. For system vent paths, the correct valve position is closed. The note allows the valves needed to be open for system venting to be opened under administrative control. Since administrative control provides reasonable assurance that the valves can be closed in a timely manner, as needed, the NRC staff concludes that the note is acceptable.

The NRC staff found that the proposed SRs meet the regulatory requirements of 1 O CFR 50.36 because they provide assurance that the necessary quality of systems and components will be maintained and that the LCOs will be met. Therefore, the NRC staff finds the proposed amendment acceptable.

The regulation at 1 O CFR 50.36(a)(1) states, in part, that: "A summary statement of the bases or reasons for such specifications... shall also be included in the application, but shall not become part of the technical specifications." The licensee may make changes to the TS Bases without prior NRC staff review and approval in accordance with the TS Bases Control Program described in TS 6.8.4.h. Accordingly, along with the proposed TS changes, the licensee also submitted TS Bases changes, for information only, corresponding to the proposed TS changes.

The NRC staff determined that TS Bases changes are consistent with the proposed TS changes and provide the purpose for each requirement in the specification consistent with the Commission's Final Policy Statement on TSs Improvements for Nuclear Power Reactors dated July 22, 1993 (58 FR 39132).

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 1 O 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 (79 FR 52064). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 1 O 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) 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: M. Hamm Date: May 11, 2015

ML15083A403

concur via SE dated 2127 /15 OFFICE LPL 1-2/PM LPL 1-2/LA STSB/BC OGC NAME REnnis ABaxter**

RElliott*

DStraus**

DATE 4/22/15 4/17/15 2/27/15 4/22/15

v t e Letter Sequence Approval
TAC:MF4412, Generic Letter 2008-01, Managing Gas Accumulation, TSTF-5 (Approved, Closed) TAC:MF4413, Generic Letter 2008-01, Managing Gas Accumulation, TSTF-5 (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2014-07-31 [Table View]

ML15083A403

Text

SUBJECT:

Dear Mr. Hanson:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

2.1 Background

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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