RA-17-055, License Amendment Request to Implement BWRVIP-18, Revision 2-A

License Amendment Request to Implement BWRVIP-18, Revision 2-A

ML17242A211
Person / Time
Site:	Oyster Creek
Issue date:	08/30/2017
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-17-055
Download: ML17242A211 (15)

Text

Exelon Generation RA-17-055 August 30, 2017 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRG Docket No. 50-219 10 CFR 50.90

SUBJECT:

License Amendment Request to Implement BWRVIP-18, Revision 2-A Pursuant to 1 O CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes a change to a License Condition of Renewed Facility Operating License No. DPR-16 for Oyster Creek Nuclear Generating Station (OCNGS).

The proposed change revises OCNGS Renewed Operating License Section 2.C, License Condition (5) to adopt BWRVIP-18, Revision 2-A, "BWR Vessel and Internals Project, BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines." This change is consistent with the Nuclear Regulatory Commission (NRG) approval of BWRVIP-18, Revision 2-A, issued in NRG letter dated December 21, 2016. BWRVIP-18, Revision 2 was approved in NRG letter dated February 22, 2016, entitled, Final Safety Evaluation for Electric Power Research Institute Topical Report "BWRVIP-18, Revision 2: Boiling Water Reactor Vessel and Internals Project, Boiling Water Reactor Core Spray Internals Inspection and Flaw Evaluation Guidelines."

Exelon has concluded that the proposed change presents no significant hazards consideration under the standards set forth in 1 O CFR 50.92.

The proposed change has been reviewed by the OCNGS Plant Operations Review Committee in accordance with the requirements of the Exelon Quality Assurance Program.

This amendment request contains no regulatory commitments. provides the evaluation of the proposed change. Attachment 2 provides a copy of the marked up Renewed Operating License page that reflects the proposed change. No change to the OCNGS Technical Specifications is required.

Exelon requests approval of the proposed amendment by August 31, 2018 in order to utilize the proposed change in the Fall 2018 Refueling Outage which is currently scheduled to start on September 17, 2018. Upon NRG approval, the amendment shall be implemented within 60 days of issuance.

License Amendment Request License Condition 2.C.(5): BWRVIP-18, Rev. 2-A Docket No. 50-219 August30,2017 Page 2 In accordance with 1 O CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the State of New Jersey of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact David J. Distel at 610-765-5517.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 301h day of August 2017.

Respectfully, James Barstow Director, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. Evaluation of Proposed Change

2. Markup of Proposed Renewed Operating License Page cc:

USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, OCNGS USNRC Project Manager, OCNGS Manager, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGE License Amendment Request Oyster Creek Nuclear Generating Station Docket No. 50-219

Subject:

License Amendment Request to Implement BWRVIP-18, Revision 2-A 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

License Amendment Request License Condition 2.C.(5): BWRVIP-18, Rev. 2-A Docket No. 50-219 Evaluation of Proposed Change 1.0

SUMMARY

DESCRIPTION Page 1 of 10 Pursuant to 1 O CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes a change to a License Condition of Renewed Facility Operating License No. DPR-16 for Oyster Creek Nuclear Generating Station (OCNGS).

The existing OCNGS Renewed Operating License Condition 2.C.(5) specifies that inspections of Core Spray spargers, piping and associated components will be performed in accordance with BWRVIP-18, Revision 0, as approved by NRG staff's Final Safety Evaluation Report dated December 2, 1999.

The proposed change will revise OCNGS Renewed Operating License Section 2.C, License Condition (5) to adopt BWR Vessel & Internals Project (BWRVIP) BWRVIP-18, Revision 2-A, "BWR Vessel and Internals Project, BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines," EPRI Technical Report (TR) 3002008089. This change is consistent with the Nuclear Regulatory Commission (NRG) approval of BWRVIP-18, Revision 2-A, issued in NRG letter dated December 21, 2016. BWRVIP-18, Revision 2 was approved in NRG letter dated February 22, 2016, entitled, Final Safety Evaluation for Electric Power Research Institute Topical Report "BWRVIP-18, Revision 2: Boiling Water Reactor Vessel and Internals Project, Boiling Water Reactor Core Spray Internals Inspection and Flaw Evaluation Guidelines."

2.0 DETAILED DESCRIPTION The proposed change revises OCNGS Renewed Operating License Section 2.C, License Condition (5) to adopt BWRVIP-18, Revision 2-A, "BWR Vessel and Internals Project, BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines." This change is consistent with the Nuclear Regulatory Commission (NRG) approval of BWRVIP-18, Revision 2-A, issued in NRG letter dated December 21, 2016. BWRVIP-18, Revision 2 was approved in NRG letter dated February 22, 2016, entitled, Final Safety Evaluation for Electric Power Research Institute Topical Report "BWRVIP-18, Revision 2: Boiling Water Reactor Vessel and Internals Project, Boiling Water Reactor Core Spray Internals Inspection and Flaw Evaluation Guidelines."

The NRG approval letter dated February 22, 2016, concluded that the EPRI TR provides an acceptable technical justification with respect to the proposed inspections and flaw evaluation guidelines for the BWR Core Spray components, and determined that the EPRI TR was acceptable for licensee usage considering the NRG staff requirements and recommendations specified in Section 5.0 of the NRG Safety Evaluation for Topical Report BWRVIP-18, Revision 2, "BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines." The NRG staff's safety evaluation report requirements have been incorporated into BWRVIP-18, Revision 2-A, as identified in NRG letter dated December 21, 2016 approving the report "BWRVIP-18, Revision 2-A: BWR Vessel and Internals Project, Core Spray Internals Inspection and Evaluation Guidelines," EPRI Technical Report 3002008089.

Implementation of BWRVIP-18, Revision 2-A provides relaxed inspection requirements for the Core Spray piping and components currently required to be inspected in the OCNGS OC1 R27 refuel outage (Fall 2018). The NRG SER dated February 22, 2016 determined that the revised reduction in inspection frequency provides an acceptable level of quality for the inspection and flaw evaluation of the Core Spray piping and sparger systems.

License Amendment Request License Condition 2.C.(5): BWRVIP-18, Rev. 2-A Docket No. 50-219 Evaluation of Proposed Change Page 2 of 10 Inspections of applicable Core Spray spargers, piping and associated components will be deferred from the OC1 R27 refuel outage in accordance with the BWRVIP-18, Revision 2-A, inspection frequency requirements.

The proposed change to the OCNGS Renewed Operating License is summarized below:

1. The proposed change would revise the License Condition 2.C.(5) wording to incorporate reference to BWRVIP-18, Revision 2-A, as approved by NRC staff's Final Safety Evaluation Report dated February 22, 2016 and subsequently approved by NRC letter dated December 21, 2016, for OCNGS.

The marked up page that reflects the proposed change is provided in Attachment 2 (Renewed Operating License page). No change to the OCNGS Technical Specifications is required.

3.0 TECHNICAL EVALUATION

The purpose of the Core Spray System is to provide for the removal of the decay heat from the core following a postulated Loss-of-Coolant Accident (LOCA), so that fuel clad melting is prevented for the entire spectrum of postulated LOCAs.

The Core Spray System delivers a low pressure spray pattern over the fuel following a LOCA, to limit peak clad temperature below 2200°F. Other criteria which are met by the Core Spray System are as follows:

a. Local oxidation shall not exceed a thickness greater than 17% of unoxidized clad.

b. Hydrogen generation from the metal water reaction shall not exceed one percent of the calculated value for the total metal-water reaction hydrogen generation.

c. A coolable geometry must be maintained.

d. Long term cooling must be provided.

Although the reactor Feedwater System can supply an adequate amount of cooling water to replace that lost through an extended range of pipe break sizes (as long as normal plant auxiliary power is available), the Core Spray System provides an alternate supply of cooling water which is independent of the Feedwater System and which can be operated on emergency power.

The Core Spray System is a low pressure system which supplies cooling water when reactor pressure is reduced to about 285 psig. The system will supply cooling water before the reactor overheats after large or intermediate pipe breaks. To accommodate some intermediate to small pipe breaks, when the Feedwater System is not available, the Automatic Depressurization System (UFSAR Subsection 6.3.1.2) will provide the initial controlled blowdown to reduce reactor pressure, and thus permit Core Spray System actuation before the fuel uncovers and overheats.

Implementation of BWRVIP-18, Revision 2-Quality and Reporting Requirements Since the December 2, 1999 SER for BWRVIP-18, Revision O currently referenced in the OCNGS Renewed Operating License, the TR has been revised twice. The first revision issued October 2008 incorporated inspection recommendations for inaccessible welds as described in

License Amendment Request License Condition 2.C.(5): BWRVIP-18, Rev. 2-A Docket No. 50-219 Evaluation of Proposed Change Page 3 of 10 BWRVIP-168. For all welds considered to be inaccessible, the TR identified similar welds in both trains of the Core Spray System. These similar welds were then used as indicators to drive assessment of inaccessible welds. This approach was found appropriate by the NRC staff based on the relatively larger population of accessible welds than inaccessible welds of each type of weld along with the assertion that degradation is likely to be self-similar (Reference 4).

The staff's SER for BWRVI P-18, Revision 1 concluded that the additional guidance added to the TR regarding inaccessible welds was technically sound and provided a sufficient conservative and quality method of controlling for crack identification in the subject welds (Reference 4).

The subject TR was then updated April 2012 to Revision 2 to incorporate the results of inspection optimization as documented in BWRVIP-251. Additional guidance was imposed by the N RC staff on BWRVI P-18, Revision 2 following staff review of the revised guidelines. This guidance was issued as conditions in the Safety Evaluation which were subsequently incorporated into BWRVIP-18, Revision 2-A.

Since BW RVI P-18 was first issued in 1996, a vast amount of inspection data had been collected on the Core Spray Systems in the BWR industry. That data, together with other operational data, was evaluated in light of the current understanding of IGSCC and other failure mechanisms. The result was a revision to the Core Spray inspection recommendations that was documented in BWRVIP-251 (Technical Basis for Revision of the BWRVIP-18 Core Spray Inspection Program). BWRVIP-18, Revision 2 then presented the revised inspection program.

For some Core Spray System locations, the frequency of inspections was increased; for other locations, it was decreased. Overall, the current recommendations require fewer inspections while maintaining a level of safety consistent with the original version of the guidelines (Reference 6). Revision 2 to BWRVIP-18 was reviewed and approved by the NRC, as modified by conditions set forth in the staff's SER (Reference 1 ).

The use of BWRVIP-18, Revision 2 for the BWR industry has been reviewed and approved by NRC Safety Evaluation Report dated February 22, 2016 (Reference 1 ). In this SER, the NRC staff performed a review of the TR to determine whether the newly revised reduction in inspection frequency provides an acceptable level of quality for the inspection and flaw evaluation of the Core Spray piping and sparger systems. This SER concludes that the BWRVIP's proposed inspection plan is acceptable with the Conditions addressed in Section 5.0 of this SE. The technical evaluation found within BWRVIP-18, Revision 2 remains applicable for the BWR industry and OCNGS use, as supplemented by conditions provided in the NRC staff's SER.

Although BWRVI P-18 no longer contains its own reporting requirements, reporting guidance is now contained elsewhere in BWRVIP requirements. OCNGS License Renewal commitment A.5.9.8 requires OCNGS to follow BWRVIP guidelines. These guidelines, including BWRVIP-94, are implemented at OCNGS in accordance with this license renewal commitment. BWRVIP-94 now contains the relevant program reporting guidance, requiring the utility to provide inspection results to the BWRVIP Program Manager. According to BWRVIP-94, "Licensees shall forward a summary of all inspections, associated results and new repairs to the BWRVIP Program Manager within 120 days following completion of an outage." The BWRVIP then compiles these inspection summaries and provides them to the NRC on a regular basis. This current BWRVIP-94 reporting requirement is considered similar to previous BWRVI P-18 requirements (Reference 10).

License Amendment Request License Condition 2.C.(5): BWRVIP-18, Rev. 2-A Docket No. 50-219 Evaluation of Proposed Change Page 4 of 10 Additionally, BWRVIP-94, Revision 2 guidance states that flaw evaluations performed in accordance with the guidance in BWRVIP reports for the acceptance of inspection results do not require transmittal to, or approval by, the NRC. However, nothing in the BWRVIP documents supersedes ASME Section XI requirements for reporting flaws and flaw evaluations. For flaws not meeting the above statement, BWRVIP-94, Revision 2 requires that flaw evaluations that deviate from the guidance in BWRVIP reports (e.g., assumptions, methods, acceptance criteria, etc.) shall be submitted to the NRC. If the flaw evaluation is later revised, the results shall be communicated to the NRC (Reference 10).

The applicable reporting requirements for Core Spray inspection results previously contained within BWRVI P-18 are now contained within other BWR industry commitments in the license renewal term of operation. For a BWR utility reporting of outage findings, it is therefore acceptable to eliminate the referenced implementation requirement for BWRVIP-18 as approved December 2, 1999. Upon NRC approval of this License Amendment Request, the OCNGS commitment will change to implement BWRVIP-18 as approved by the NRC Safety Evaluation dated February 22, 2016.

OCNGS Inspection History of Reactor Internals Core Spray Piping and Spargers In 1978 and 1980, possible cracking was identified on the Core Spray System. These findings resulted in increased NRC involvement at OCNGS to ensure that the appropriate inspections were performed. Additional plant specific inspection requirements for NRC review and approval prior to plant startup were added to the OCNGS Operating License. After OCNGS operating experience identified no new cracking, inspection requirements were revised in accordance with an NRC SER dated November 3, 2000 to allow implementation of BWRVIP-18, as approved by NRC staff's Final Safety Evaluation Report (SER) dated December 2, 1999. A review of BWRVIP inspection summaries, submitted to the NRC since the BWRVIP-18 December 2, 1999 SER, has indicated that no new cracking was identified associated with reactor internals Core Spray spargers or piping (Reference 5). Since initial discovery, all locations with possible cracking identified have either been structurally repaired or inspection has shown that the indications were not actual cracks. Inspection in accordance with BWRVIP-18 has identified no new cracking since possible cracking was first found in 1978 and 1980.

Additionally, the inaccessible weld program for Core Spray has been successfully implemented consistent with BWRVIP guidance. BWRVIP-18 requires that all hidden I inaccessible welds associated with the Core Spray System be documented and that a representative population of accessible welds be assigned and used to predict the condition of each of the hidden welds. For a BWR-2 such as OCNGS, only the P4a and the pg welds are defined as inaccessible and are discussed below.

P4a Welds:

The P4a weld in the BWR/2 design is a non-creviced inlet pipe to elbow weld (thermal sleeve to elbow weld). The weld is located inside the Reactor Pressure Vessel Core Spray nozzle blend radius and is inaccessible or only partially accessible for inspection. These P4a welds have been assessed by OCNGS according to the inaccessible weld program defined in BWRVIP-18.

No similar welds are currently defined as cracked in accordance with the inaccessible weld program.

License Amendment Request License Condition 2.C.(5): BWRVIP-18, Rev. 2-A Docket No. 50-21 g Evaluation of Proposed Change pg welds:

Page 5 of 10 The four pg welds in the BWR/2 (PgA, PgB, pgc and pgD) connect the shroud to the sparger tee, which is also supported by a bracket attached to the inside of the shroud. Thus, the pg weld is redundant, and no inspection is needed in accordance with BWRVIP-18 requirements.

Acceptable margins for sparger brackets provide a redundant load carrying capability for weld pg in BWR/2 designs and ensure the integrity of the weld connection even if acceptable margins are not maintained for weld pg_ All pg welds have been assessed in accordance with BWRVIP-18 requirements for an inaccessible weld program. The welds identified in BWRVIP-18 as providing redundancy for the pg weld have been inspected in accordance with BWRVI P-18 requirements with no cracking identified.

Impact on UFSAR Safety Analyses:

A review of OCNGS UFSAR Safety Analyses contained within Chapter 15 of the UFSAR (Reference 7) determined that the evaluated change will not impact the site safety analyses.

The proposed change impacts inspection and evaluation methods without changing system design or configuration. Inspection and evaluation methodologies presented within BWRVIP-18, Revision 2 as approved by NRG Safety Evaluation Report, ensure appropriate inspections and evaluations are performed to assess functionality of the Reactor Internal Core Spray piping and spargers.

Conclusion This change is consistent with the Nuclear Regulatory Commission (NRG) approval of BWRVIP-18, Revision 2-A, issued in NRG letter dated December 21, 2016. BWRVIP-18, Revision 2 was approved in NRG letter dated February 22, 2016, entitled, Final Safety Evaluation for Electric Power Research Institute Topical Report "BWRVIP-18, Revision 2: Boiling Water Reactor Vessel and Internals Project, Boiling Water Reactor Core Spray Internals Inspection and Flaw Evaluation Guidelines." The NRG staff SER found that the Topical Report BWRVIP-18, Revision 2, is acceptable for referencing in license applications for nuclear power plants to the extent specified and under the limitations delineated in the Topical Report and in the NRG SER. The NRG staff's safety evaluation report requirements have been incorporated into BWRVIP-18, Revision 2-A, as identified in NRG letter dated December 21, 2016 approving the report "BWRVIP-18, Revision 2-A: BWR Vessel and Internals Project, Core Spray Internals Inspection and Evaluation Guidelines," EPRI Technical Report 300200808g.

Based on prior NRG approval of BWRVIP-18, Revision 2, as well as a review of prior exams performed on Core Spray spargers and piping, the proposed change for Oyster Creek Nuclear Generating Station to update the existing OCNGS Renewed Operating License Condition 2.C.(5) to adopt Technical Report (TR) BWRVIP-18, Revision 2-A, "BWR Vessel and Internals Project, BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines," will continue to ensure a high level of safety and quality for the reactor internals Core Spray piping and spargers.

License Amendment Request License Condition 2.C.(5): BWRVIP-18, Rev. 2-A Docket No. 50-219 Evaluation of Proposed Change

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria Page 6 of 10 1 O CFR 50, Appendix K, Section D, provides criteria for cooling the core with the Core Spray System under loss-of-coolant accident (LOCA) conditions. The Core Spray and sparger assembly provides the flow path from the Reactor Pressure Vessel (RPV) nozzle to provide uniform distribution of spray to assure cooling when the core cannot be flooded. Any leak from the Core Spray piping into the RPV annulus region is potentially unavailable for core cooling during the event when Core Spray operation is postulated. Inspection of the Core Spray spargers, piping and associated components ensures potential leakage is maintained below tolerable limits to ensure peak cladding temperature remains below the plant-specific LOCA analysis.

The proposed Renewed Operating License change revises License Condition 2.C.(5) to require inspections of Core Spray spargers, piping and associated components to be performed in accordance with BWRVIP-18, Revision 2-A, as approved by NRG staff's Final Safety Evaluation Report, and issued in NRG letter dated December 21, 2016.

Exelon has evaluated the proposed change against the applicable regulatory requirements and acceptance criteria. This change is consistent with the Nuclear Regulatory Commission (NRG) approval of BWRVIP-18, Revision 2-A, issued in NRG letter dated December 21, 2016.

BWRVIP-18, Revision 2 was approved in NRG letter dated February 22, 2016, entitled, Final Safety Evaluation for Electric Power Research Institute Topical Report "BWRVIP-18, Revision 2:

Boiling Water Reactor Vessel and Internals Project, Boiling Water Reactor Core Spray Internals Inspection and Flaw Evaluation Guidelines." The NRG staff SER found that the Topical Report BWRVIP-18, Revision 2, is acceptable for referencing in license applications for nuclear power plants to the extent specified and under the limitations delineated in the Topical Report and in the NRG SER, during either a facility's current operating term or extended license period.

The inspection plan for the Core Spray spargers, piping and associated components in accordance with BWRVIP-18, Revision 2-A, with the Conditions addressed in Section 5.0 of the NRG SER dated February 22, 2016, provides adequate assurance that the Core Spray System can perform its safety function as required by the plant-specific LOCA-analysis. This satisfies the requirements of 1 O CFR 50, Appendix K, Section D regarding adequate heat removal by the Emergency Core Cooling System (ECCS) and continues to assure that the underlying criteria of the License Condition is met. Based on this, there is reasonable assurance that the health and safety of the public, following approval of this License Condition change, is unaffected.

4.2 Precedent Although there were no specific precedent LAR submittals identified, the use of BWRVIP-18, Revision 2 for the BWR industry has been reviewed and approved by NRG Safety Evaluation Report dated February 22, 2016 (Reference 1 ). In this SER, the NRG staff performed a review of the TR to determine whether the newly revised reduction in inspection frequency provides an acceptable level of quality for the inspection and flaw evaluation of the Core Spray piping and sparger systems. This SER concludes that the BWRVIP's proposed inspection plan is acceptable with the Conditions addressed in Section 5.0 of this SE. The technical evaluation

License Amendment Request License Condition 2.C.(5): BWRVIP-18, Rev. 2-A Docket No. 50-219 Evaluation of Proposed Change Page 7 of 10 found within BWRVIP-18, Revision 2 remains applicable for the BWR industry and OCNGS use, as supplemented by conditions provided in the NRC staff's SER.

4.3 No Significant Hazards Consideration Exelon Generation Company, LLC (Exelon) is proposing a change to the OCNGS Renewed Operating License Condition 2.C.(5) to allow performance of inspections of Core Spray spargers, piping and associated components in accordance with BWRVIP-18, Revision 2-A, as approved by NRC letter dated December 21, 2016.

Exelon has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 1 O CFR 50.92, "Issuance of amendment," as discussed below:

1.

Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No. The proposed change to the License Condition 2.C.(5) requirements for inspection of Core Spray spargers, piping and associated components does not alter the use of the inspection methods and criteria used to determine the capability of the Core Spray System to perform its intended safety function that have been previously reviewed and approved by the NRC. The proposed change is in accordance with an NRC approved inspection and flaw evaluation guideline and as such, maintains required safety margins. The proposed change does not adversely affect accident initiators or precursors, nor does it alter the design assumptions, conditions, or configuration of the facility or the manner in which the plant is operated and maintained.

The proposed change does not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed change does not require any physical change to any plant SSCs nor does it require any change in systems or plant operations. The proposed change is consistent with the safety analysis assumptions and resultant consequences.

Incorporating NRG-approved inspection frequency and criteria for Core Spray spargers, piping and associated components has no physical effect on plant equipment and therefore, no impact on the course of plant transients.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No. The proposed incorporation of NRG-approved inspection frequency and criteria for Core Spray spargers, piping and associated components is a change based upon previously approved documents and does not involve changes to the plant hardware or its operating characteristics. As a result, no new failure modes are being introduced. There are no hardware changes nor are there any changes in the method by

License Amendment Request License Condition 2.C.(5): BWRVIP-18, Rev. 2-A Docket No. 50-219 Evaluation of Proposed Change Page 8 of 10 which any plant systems perform a safety function. No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed change.

The proposed change does not introduce any new accident precursors, nor does it involve any physical plant alterations or changes in the methods governing normal plant operation. The change does not alter assumptions made in the safety analysis.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Do the proposed changes involve a significant reduction in a margin of safety?

Response: No. The margin of safety is established through the design of the plant structures, systems, and components, and through the parameters for safe operation and setpoints for the actuation of equipment relied upon to respond to transients and design basis accidents. The use of inspection frequency and criteria for Core Spray spargers, piping and associated components in accordance with NRG-approved methods, guidelines, and criteria provides adequate assurance that the Core Spray System can perform its safety function as required by the plant-specific LOCA-analysis.

Therefore, the proposed change does not decrease the margin of safety. The proposed change in inspection criteria maintains the current safety margin, which protects the fuel cladding integrity during a postulated LOCA event, but does not change the requirements governing operation or availability of safety equipment assumed to operate to preserve the margin of safety. The change does not alter the behavior of plant equipment, which remains unchanged.

The proposed change to License Condition 2.C.(5) is consistent with NRG-approved methods, guidelines, and criteria and provides adequate assurance that the Core Spray System can perform its safety function as required by the plant-specific LOCA-analysis.

No setpoints at which protective actions are initiated are altered by the proposed change.

The proposed change does not alter the manner in which the safety limits are determined. This change is consistent with plant design and does not change the Technical Specification operability requirements; thus, previously evaluated accidents are not affected by this proposed change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Exelon concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 1 O CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

License Amendment Request License Condition 2.C.(5): BWRVIP-18, Rev. 2-A Docket No. 50-219 Evaluation of Proposed Change

5.0 ENVIRONMENTAL CONSIDERATION

Page 9 of 10 A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 1 O CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 1 O CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Letter from Kevin Hsueh (USN RC) to Tim Hanley (Chairman, BWR Vessel and Internals Project (Exelon)), "Final Safety Evaluation For Electric Power Research Institute Topical Report "BWRVIP-18, Revision 2: Boiling Water Reactor Vessel and Internals Project, Boiling Water Reactor Core Spray Internals Inspection and Flaw Evaluation Guidelines, dated February 22, 2016.

2. Letter from Kevin Hsueh (USN RC) to Tim Hanley (Chairman, BWR Vessel and Internals Project (Exelon)), "U.S. Nuclear Regulatory Commission Approval Letter For Electric Power Research Institute Topical Report, BWRVIP-18, Revision 2-A, "BWR [Boiling Water Reactor]

Vessel and Internals Project, BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines," dated December 21, 2016.

3. BWRVIP-18, Revision 2-A: BWR Vessel and Internals Project, BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines. EPRI, Palo Alto, CA: 2016. 3002008089.

4. Letter from Robert A. Nelson (USNRC) to David Czufin (Chairman, BWR Vessel and Internals Project (Exelon)), "Final Safety Evaluation for Electric Power Research Institute Boiling Water Reactor Vessel and Internals Project Topical Report 1016568, 'BWRVI P-18, Revision 1: BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines' (TAC NO. ME2189), dated January 30, 2012.

5. EPRI Letter 2017-082, "BWRVIP Inspection Summaries for Fall 2016 Outages" July 5, 2017.

6. BWRVIP-18, Revision 2: BWR Vessel and Internals Project, BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines. EPRI. Palo Alto, CA: 2012. 1025059.

7. Oyster Creek UFSAR Revision 19, October 2015.

8. Letter from Jack R. Strosnider (USNRC) to Carl Terry (Chairman, BWR Vessel and Internals Project (Niagara Mohawk Power Company)), "Final Safety Evaluation of BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines (BWRVIP-18)", dated December 2, 1999.

License Amendment Request License Condition 2.C.(5): BWRVIP-18, Rev. 2-A Docket No. 50-219 Evaluation of Proposed Change Page 10 of 10

9. Letter from Helen N. Pastis (USN RC) to Ronald DeGregorio (Vice President Oyster Creek),

"Oyster Creek Nuclear Generating Station - Issuance of Amendment RE: Core Spray Spargers (TAC No. MA8560)", dated November 3, 2000 (ML003759598).

10. BWRVIP-94NP, Revision 2: BWR Vessel Internals Project, Program Implementation Guide.

EPRI, Palo Alto, CA: 2011. 1024452.

ATTACHMENT 2 Markup of Proposed Renewed Operating License Page License Amendment Request Oyster Creek Nuclear Generating Station Docket No. 50-219 License Amendment Requestto Implement BWRVIP-18, Revision 2-A Renewed Operating License Page 4

4 -

(4)

Exelon Generation Company shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 1 O CFR 50.90 and 1 O CFR 50.54(p). The combined set of plans 1, submitted by letter dated May 17, 2006, is entitled: "Oyster Creek Nuclear Generating Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 5."

The set contains Safeguards Information protected under 1 O CFR 73.21.

Exelon Generation Company shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP),

including changes made pursuant to the authority of 1 O CFR 50.90 and 1 O CFR 50.54(p). The Exelon Generation Company CSP was approved by Renewed License Amendment No. 280 and modified by License Amendment No. 288.

(5)

Inspections of core spray spargers, piping and associated components will be performed in accordance with BWRVIP-18, "BWR Core Spray Internals Inspection and Flaw Evaluation Guidelines," as approved by NRC staff's Final Safety Evaluation Report dated December 2, 1999 February 22, 2016 and subsequently approved by NRC letter dated December 21, 2016.

(6)

Long Range Planning Program - Deleted (7)

Reactor Vessel Integrated Surveillance Program Exelon Generation Company is authorized to revise the Updated Final Safety Analysis Report (UFSAR) to allow implementation of the Boiling Water Reactor Vessel and Internals Project reactor pressure vessel Integrated Surveillance Program as the basis for demonstrating compliance with the requirements of Appendix H to Title 1 O of the Code of Federal Regulations Part 50, "Reactor Vessel Material Surveillance Program Requirements," as set forth in the licensee's application dated December 20, 2002, and as supplemented on May 30, September 1 O,and November 3, 2003.

All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of the most recent NRQ-approved version of the Boiling Water Reactor Vessel and Internals Project Integrated Surveillance Program appropriate for the configuration of the specimens in the capsule. Any changes to the capsule withdrawal schedule, including spare capsules, must be approved by the NRC prior to implementation. All capsules placed in storage must be maintained for future insertion. Any changes to storage requirements must be approved by the NRC, as required by 1 O CFR Part 50, Appendix H.

1The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.

Renewed License No. DPR-16 Amendment No. ~