ML16335A038

Issuance of Amendments to Revise Technical Specification Snubber Requirements

ML16335A038
Person / Time
Site:	Limerick
Issue date:	12/29/2016
From:	Richard Ennis Plant Licensing Branch 1
To:	Bryan Hanson Exelon Nuclear
Ennis R, NRR/DORL/LPLI-II, 415-1420
References
CAC MF7541, CAC MF7542
Download: ML16335A038 (27)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 29, 2016 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS TO REVISE SNUBBER REQUIREMENTS (CAC NOS. MF7541 AND MF7542)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment Nos. 223 and 184 to Renewed Facility Operating License Nos. NPF-39 and NPF-85 for the Limerick Generating Station, Units 1 and 2, respectively. These amendments consist of changes to the technical specifications (TSs) in response to your application dated March 29, 2016, as supplemented by letter dated September 6, 2016. The amendments revise the TS requirements for snubbers.

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

Sincerely,

• -EB~

~ V. Sreenivas, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 223 to Renewed NPF-39

2. Amendment No. 184 to Renewed NPF-85

3. Safety Evaluation cc w/enclosures: 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 RENEWED FACILITY OPERATING LICENSE Amendment No. 223 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 March 29, 2016, as supplemented by letter dated September 6, 2016, 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.

Enclosure 1

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. 223, 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 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION Stephen S. Koenick, Acting Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: December 2 9 , 2O1 6

ATTACHMENT TO LICENSE AMENDMENT NO. 223 LIMERICK GENERATING STATION, UNIT 1 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 a marginal line 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 3/4 7-11 3/4 7-11 3/4 7-11a 3/4 7-11a 3/4 7-11b 3/4 7-12 3/4 7-12 3/4 7-13 3/4 7-14 3/4 7-15 3/4 7-16 6-14d 6-14d 6-14e

(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 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 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 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. 223, 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. 223

PLANT SYSTEMS 3/4.7.4 SNUBBERS LIMITIN~ CQNDITION FOR. OPERATION 3.7.4 All snubbers shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3. OPERATIONAL CONDITIONS 4 and 5 for snubbers located on systems required OPERABLE in those OPERATIONAL CONDITIONS.

ACTION:

With one or more snubbers inoperable on any system, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber(s) to OPERABLE status and perform an engineering evaluation per the Snubber Program on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for that system.

SURVEILLANCE REQUIREMENTS 4.7.4 Each snubber shall be demonstrated OPERABLE by performance of the Snubber Program.

LIMERICK - UNIT 1 3/4 7-11 Amendment No. -51:, 2 2 3

PLANT SYSTEMS TABLE 4.7.4.1 (Deleted)

TEOiNICAL SPECIFICATION PAGES 3/4 7-lla THROUGH 3/4 7-llb HAVE BEEN INTENTIONALLY OMITTED LIMERICK - UNIT 1 3/4 7-lla Amendment No. 5+/-, 223

PLANT SYSTEMS SURVEILLANCE REOUIREME&TS (Continued)

THE INFORMATION FROM TECHNICAL SPECIFICATIONS SECTION 4.7.4.d HAS BEEN RELOCATED TO THE TECHNICAL REQUIREMENTS MANUAL (TRM) SNUBBERS SECTION. TECHNICAL SPEOFICATIONS PAGES 3/4 7-13 THROUGH 7-16 OF THIS SECTION HAVE BEEN INTENTIONALLY OMITTED.

LIMERICK - UNIT 1 3/4 7-12 Amendment No. :l, 2 2 3

bDMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

i. Battery Monitoring and Maintenance Program This Program provides for restoration and maintenance, based on the recorrunendations of IEEE Standard 450, "IEEE Recorrunended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries For Stationary Applications,n of the following:

a. Actions to restore battery cells wi~h float voltage < 2.13 volts, and

b. Actions to equalize and test battery cells that have been discovered with electrolyte level below the minimum established design limit.

j. Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NE! 04-10, "Risk-Informed Method for Control of Surveillance Frequencies,"

Revision 0.

c. The provisions of Surveillance Requirements 4. 0. 2 and 4. 0. 3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

k. Snubber Program This program conforms to the examination, testing, and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR

50. 55a inservice inspection ( ISI) requirements for supports. 'l'he program shall be in accordance with the following:

a. This program shall meet 10 CFR 50. 55a ISI requirements fer supports.

b. The program shall meet the requirements for ISI of supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that a.!:'e incorporated by reference in 10 CFR 50.55a, subject to its conditions, and subject to Comrnission approval.

LIMERICK - UNIT 1 6-14d Amendment No. ~' ~' 223

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

c. The program shail, as allowed by 10 CFR 50.55a, meet Subsection ISTA, "General Requirements," and Subsection ISTD, "Preservice and lnservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," in lieu of Section XI of the ASME B&PV Code ISI requirements for snubbers, or meet authorized alternatives pursuant to 10 CFR 50.55a.

d. The 120-month program updates shall be made in accordance with 10 CFR 50.55a subject to the limitations and conditions listed therein.

LIMERICK lJNIT l 6-14e Amendment No. 2 2 3

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 RENEWED FACILITY OPERATING LICENSE Amendment No. 184 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 March 29, 2016, as supplemented by letter dated September 6, 2016, 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.

Enclosure 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 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. 184, 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 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION Stephen S. Koenick, Acting Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: December 2 9, 2O1 6

ATTACHMENT TO LICENSE AMENDMENT NO. 184 LIMERICK GENERATING STATION, UNIT 2 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 a marginal line 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 3/4 7-11 3/4 7-11 3/4 7-11a 3/4 7-11a 3/4 7-11b 3/4 7-12 3/4 7-12 3/4 7-13 3/4 7-14 3/4 7-15 3/4 7-16 6-14d 6-14d 6-14e

(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 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 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 B, as revised through Amendment No. 184, 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. 184

PLANT SYSTEMS 3/4.7.4 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.4 All snubbers shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3. OPERATIONAL CONDITIONS 4 and 5 for snubbers located on systems required OPERABLE in those OPERATIONAL CONDITIONS.

ACTION:

With one or more snubbers inoperable on any system, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber(s) to OPERABLE status and perform an engineering evaluation per the Snubber Program on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for that system.

S_UIW~+LL_ANCE filQUIREM_ENT~

4.7.4 Each snubber shall be demonstrated OPERABLE by performance of the Snubber Program.

LIMERICK - UNIT 2 3/4 7-11 Amendment No. -1, 5, 18 4

PLANT SYSTEMS TABLE 4.7.4.1 (Deleted)

TECHNICAL SPECIFICATION PAGES 3/4 7-lla THROUGH 3/4 7-llb HAVE BEEN INTENTIONALLY OMITTED LIMERICK - UNIT 2 3/4 7-lla Amendment No. +/-5, 184

PLANT SYSTEMS

~UlWEILLANC::E R~QUIR~M~NT~ (C::onti nued)

THE INFORMATION FROM TECHNICAL SPECIFICATIONS SECTION 4.7.4.d HAS BEEN RELOCATED TO THE TECHNICAL REQUIREMENTS MANUAL (TRM) SNUBBERS SECTION. TECHNICAL SPECIFICATIONS PAGES 3/4 7-13 THROUGH 7-16 OF THIS SECTION HAVE BEEN INTENTIONALLY OMITTED.

LIMERICK - UNIT 2 3/4 7-12 Amendment No. :1:-5, 184

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

i. Battery Monitoring and Maintenance Program This Program provides for restoration and maintenance, based on the recommendations of IEEE Standard 450, IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries For Stationary Applications," of the following:

a. Actions to restore battery cells with float voltage < 2.13 volts, and

b. Actions to equalize and test battery cells that have been discovered with electrolyte level below the minimum established design limit.

j. Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NE! 04-10, Risk-Informed Method for Control of Surveillance Frequencies,"

Revision 0.

c. The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

k. Snubber Program This program conforms to the examination, testing, and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR 50.55a inservice inspection (!SI) requirements for supports. The program shall be in accordance with the following:

a. This program shall meet 10 CFR 50.55a IS! requirements for supports.

b. The program shall meet the requirements for !SI of supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that are incorporated by reference in 10 CFR 50.55a, subject to its conditions, and subject to Commission approval.

LIMERICK - UNIT 2 6-14d Amendment No. -rr6, 1:4-T, 184

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

c. The program shall, as allowed by 10 CFR 50.55a, meet Subsection ISTA, "General Requirements," and Subsection ISTD, "Preservice and lnservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," in lieu of Section XI of the ASME B&PV Code ISI requirements for snubbers, or meet authorized alternatives pursuant to 10 CFR 50.55a.

d. The 120-month program updates shall be made in accordance with 10 CFR 50.55a subject to the limitations and conditions listed therein.

LIMERICK - UNIT 2 6-14e Amendment No. 18 4

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 223 AND 184 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 March 29, 2016, as supplemented by letter dated September 6, 2016 (Agencywide Documents Access and Management System (ADAMS) Package Accession Nos. ML16090A286 and ML16251A060, respectively), Exelon Generation Company, LLC (Exelon, the licensee) submitted a license amendment request (LAR) for the Limerick Generating Station (LGS), Units 1 and 2.

The proposed amendments would revise the technical specification {TS) requirements for snubbers. Specifically, the amendments would:

(1) Revise TS Section 6.0, "Administrative Controls," to add new TS 6.8.4.k, "Snubber Program."

(2) Revise TS 3/4.7.4, "Snubbers," as follows: (a) Limiting Condition for Operation (LCO) 3.7.4 would replace the existing reference to Surveillance Requirement (SR) 4.7.4g with reference to the Snubber Program; (b) SR 4.7.4 would replace the existing reference to the augmented inservice inspection (ISi) program and SR 4.0.5 for demonstrating snubber operability with reference to the Snubber Program; (c) SRs 4.7.4a through 4.7.4c, and 4.7.4e through 4.7.4i, would be deleted; (d) SR 4.7.4d, Transient Event Inspection," would be relocated to the Technical Requirements Manual (TRM); and (e) TS Figure 4.7.4-1 would be deleted.

The supplement dated September 6, 2016, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC or the Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on May 24, 2016 (81 FR 32807).

Enclosure 3

2.0 REGULATORY EVALUATION

A dynamic restraint (snubber) is a device designed to protect components from excess shock or sway caused by seismic disturbances or other transient forces. During normal operating conditions, the snubber allows for movement in tension and compression. When an impulse event occurs, the snubber becomes activated and acts as a restraint device. The device becomes rigid, absorbs the dynamic energy, and transfers it to the supporting structure.

Licensees are required to perform the ISi and testing of snubbers is accordance with Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (B&PV Code) or the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code), and the applicable addenda, as required by Section 50.55a(g) of Title 10 of the Code of Federal Regulations (10 CFR), or 10 CFR 50.55a{b){3)(v), except where the NRC has granted relief pursuant to 10 CFR 50.55a{g)(6)(i), or authorized alternatives pursuant to 10 CFR 50.55a(z). However, the ASME B&PV Code,Section XI option no longer exists when using the 2006 Addenda and later editions and addenda of ASME B&PV Code,Section XI, because these editions and addenda of Section XI do not provide ISi provisions for snubbers.

As discussed in 10 CFR 50.55a(b)(3)(v)(B), licensees must comply with the provisions for examining and testing snubbers in Subsection ISTD of the ASME OM Code and make appropriate changes to their TSs or licensee-controlled documents when using the 2006 Addenda and later editions and addenda of Section XI of the ASME B&PV Code.

As discussed in NRC Regulatory Issue Summary (RIS) 2010-06, "lnservice Inspection and Testing Requirements of Dynamic Restraints (Snubbers)" dated June 1, 201 O (ADAMS Accession No. ML101310338):

Licensees have the option to control the ASME Code-required ISi and testing of snubbers through their TS or other licensee-controlled documents (e.g. TRM, etc.). For plants using their TS to govern ISi and testing of snubbers, 10 CFR 50.55a(g)(5)(ii) requires that if a revised ISi program for a facility conflicts with the TS, the licensee shall apply to the Commission for amendment of the TS to conform the TS to the revised program. Therefore, when performing 120-month program updates in accordance with 10 CFR 50.55a(g)(4), licensees must submit any required amendments to ensure their TS remain consistent with the new code of record or NRG-approved alternative used in lieu of the Code requirements. The TS, TRM, or other licensee-controlled documents, governing the snubber ISi and testing program, do not eliminate the 10 CFR 50.55a requirements to update the program at 120-month intervals, in accordance with 10 CFR 50.55a(g)(4), or to request and receive NRC authorization for alternatives to the Code requirements, when appropriate.

The third 10-year ISi interval at LGS began on February 1, 2007, and is scheduled to end on January 31, 2017. By letter dated March 11, 2008 (ADAMS Accession No. ML080500584), the NRC staff authorized alternative request 13R-05 to use TS 3/4.7.4 for visual examinations and functional testing of ASME Code Class 1, 2, and 3 snubbers, in lieu of the ASME B&PV Code,Section XI, IWF-5000 requirements, for the third 10-year ISi interval at LGS, Units 1 and 2.

The fourth 10-year ISi interval at LGS, Units 1 and 2, is scheduled to start on February 1, 2017, and end on January 31, 2027. For the fourth 10-year ISi interval, LGS will be using the ASME B&PV Code,Section XI, 2007 Edition, with the 2008 Addenda. For inspection and testing of snubbers during the fourth 10-year ISi interval, LGS intends to use Subsection ISTD of the ASME OM Code, 2004 Edition through 2006 Addenda, in lieu of the requirements for snubbers currently in the TSs.

The NRC's regulatory requirements related to the content of the TSs are specified in 10 CFR 50.36, "Technical specifications." Pursuant to 10 CFR 50.36, TSs are required to include items in the following 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.

As stated in 10 CFR 50.36(c)(3), 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.

NUREG-1433, Revision 4.0, "Standard Technical Specifications - General Electric BWR/4 Plants" (ADAMS Accession Nos. ML12104A192 and ML12104A193), provides guidance on TS format and content for General Electric Boiling Water Reactor/4 (BWR/4) plants. The NRC staff used the Standard Technical Specifications (STS) in NUREG-1433 as guidance in evaluating the proposed TS changes for LGS, Units 1 and 2.

3.0 TECHNICAL EVALUATION

3.1 Licensee's Proposed TS Changes The proposed changes to the LGS, Units 1 and 2, TSs are summarized below.

Proposed Change to LCO 3. 7.4 The Action statement in LCO 3.7.4 currently reads as follows:

With one or more snubbers inoperable on any system, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber(s) to OPERABLE status and perform an engineering evaluation per Specification 4.7.4g on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for that system.

As discussed in the application dated March 29, 2016, the LAR proposes to revise the above Action statement to read as follows:

With one or more snubbers inoperable on any system, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber(s) to OPERABLE status and perform an engineering evaluation per the Snubber Program on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for that system.

Proposed Changes to SR 4. 7. 4 SR 4.7.4 currently reads as follows:

Each snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program and the requirements of Specification 4.0.5.

As discussed in the application dated March 29, 2016, the LAR proposes to revise the above SR to read as follows:

Each snubber shall be demonstrated OPERABLE by performance of the Snubber Program.

In addition, the following changes would be made to SR 4.7.4:

1) SRs 4.7.4a through 4.7.4c, and 4.7.4e through 4.7.4i, would be deleted;

2) SR 4.7.4d, Transient Event Inspection," would be relocated to the TRM; and

3) TS Figure 4.7.4-1, "Sample Plan 2) for Snubber Functional Test," would be deleted.

Proposed New TS 6.8.4.k As discussed in the supplement dated September 6, 2016, the LAR proposes to revise TS Section 6.0, "Administrative Controls," to add new TS 6.8.4.k, "Snubber Program." The new TS would read as follows:

k. Snubber Program This program conforms to the examination, testing, and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR 50.55a inservice inspection (ISi) requirements for supports. The program shall be in accordance with the following:

a. This program shall meet 10 CFR 50.55a ISi requirements for supports.

b. The program shall meet the requirements for ISi of supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that are incorporated by reference in 10 CFR 50.55a, subject to its conditions, and subject to Commission approval.

c. The program shall, as allowed by 10 CFR 50.55a, meet Subsection ISTA, "General Requirements," and Subsection ISTD,

"Preservice and lnservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," in lieu of Section XI of the ASME B&PV Code ISi requirements for snubbers, or meet authorized alternatives pursuant to 10 CFR 50.55a.

d. The 120-month program updates shall be made in accordance with 10 CFR 50.55a subject to the limitations and conditions listed therein.

3.2 NRC Staff's Evaluation of Proposed Changes In Attachment 5 to the application dated March 29, 2016, the licensee provided a copy of the proposed new Snubber Program for LGS, Units 1 and 2. This licensee-controlled document would provide the requirements for snubber examination, testing, and service life monitoring in lieu of the SR 4.7.4 requirements proposed for deletion. This program would be required to be maintained in accordance with the requirements contained in proposed new TS 6.8.4.k. The program is applicable to the fourth 10-year ISi interval for LGS, Units 1 and 2, which starts on February 1, 2017. As described in Sections 1.1 and 1.6 of the program document, the LGS Snubber Program for the fourth 10-year ISi interval will be governed by the requirements of Subsection ISTD of the ASME OM Code, 2004 Edition through the 2006 Addenda, per 10 CFR 50.55a(b)(3)(v)(B).

As discussed above in Section 3.1, existing SR 4.7.4d, "Transient Event Inspection," would be relocated to the TRM. The licensee, in its supplement dated September 6, 2016, stated that ASME OM Code paragraph ISTD-1750 provides transient dynamic requirements similar to those currently contained in SR 4.7.4.d, but does not specify a time allowance for the visual inspections of accessible and non-accessible systems following the event. The licensee also stated that ISTD-1750 does not specify acceptance methods of verifying freedom of motion of inspected snubbers, which is provided in SR 4.7.4.d. For these reasons, the licensee decided to relocate the requirements in SR 4.7.4.d to the license-controlled TRM, in order to preserve the necessary details.

The NRC staff has reviewed the proposed TS changes and finds that controlling the ASME Code-required ISi and testing of snubbers through the proposed license-controlled program and licensee-controlled TRM is consistent with the guidance in RIS 2010-06. The changes are also consistent with NUREG-1433, in that the STS do not contain SRs for snubbers.

Pursuant to 10 CFR 50.55a(g), licensees are required to update their ISi programs to meet the requirements of ASME Section XI once each 10-year inspection interval. The ISi program is required to comply with the latest Edition and Addenda of ASME Section XI, incorporated by reference in 10 CFR 50.55a, 12 months prior to the start on the 10-year interval in accordance with 10 CFR 50.55a(g)(4)(ii). Based on the fourth 10-year ISi interval start date of February 1, 2017, the applicable "Code of Record" for the LGS, Units 1 and 2, fourth 10-year ISi interval is the 2007 Edition through the 2008 Addenda of the ASME B&PV Code Section XI. In accordance with 10 CFR 50.55a(b)(3)(v)(B), licensees must comply with the provisions for examining and testing of snubbers in Subsection ISTD of the ASME OM Code and make

appropriate changes to their TSs or licensee-controlled documents when using the 2006 Addenda and later editions of Section XI of the ASME B&PV Code. Accordingly, the NRC staff finds that use of Subsection ISTD of the ASME OM Code, 2004 Edition through the 2006 Addenda for the LGS Snubber Program for the fourth 10-year ISi interval is consistent with the requirements in 10 CFR 50.55a.

The NRC staff reviewed the proposed TS 6.8.4.k and the newly developed Snubber Program in to the application, and finds they are consistent with the requirements in 10 CFR 50.55a. Based on this finding, the NRC staff further finds that the examination, testing, and service life monitoring for snubbers, in accordance with the Snubber Program described in proposed TS 6.8.4.k and as required by the proposed revision to SR 4.7.4, is acceptable for demonstrating the operability of the snubbers in accordance with LCO 3.7.4. As such, the staff finds that the proposed changes continue to meet the requirements of 10 CFR 50.36(c)(3).

Based on the above considerations, the NRC staff concludes that the proposed amendments are acceptable.

The licensee's application dated March 29, 2016, provided revised TS Bases pages to be implemented with the associated TS changes. These pages were provided for information only and will be revised by the licensee in accordance with the TS Bases Control Program described in LGS TS 6.8.4.h, "Technical Specifications (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 (81 FR 32807). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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 Contributors: G. Bedi R. Ennis Date: December 29, 2016

ML16335A038 OFFICE DORL/LPL 1/PM DORL/LPL 1/LA DSS/STSB/BC DE/EPNB/BC OGC-NLO NAME REnnis LRonewicz AKlein DAiiey BMizuno DATE 12/12/16 12/6/16 12/12/16 12/14/16 12/23/16 OFFICE DORL/LPL 1/BC(A) DORL/LPL 1/PM NAME SKoenick (MMarshall for) REnnis DATE 12/29/16 12/29/16