ML20160A459

Issuance of Amendment Nos. 248 and 210 Revise Technical Specifications to Support Implementation of 10 CFR 50.69

ML20160A459
Person / Time
Site:	Limerick
Issue date:	08/07/2020
From:	V Sreenivas NRC/NRR/DORL/LPL1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Sreenivas V, 415-2597
References
EPID L-2019-LLA-0263
Download: ML20160A459 (19)

Text

August 7, 2020 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 ISSUANCE OF AMENDMENT NOS. 248 AND 210 RE: REVISE TECHNICAL SPECIFICATIONS TO SUPPORT IMPLEMENTATION OF 10 CFR 50.69 (EPID L-2019-LLA-0263)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 248 and 210 to Renewed Facility Operating License Nos. NPF-39 and NPF-85 for the Limerick Generating Station, Units 1 and 2, respectively, in response to your application dated November 25, 2019, as supplemented on May 11, 2020.

The amendments revise Technical Specification Surveillance Requirement 4.0.5, Inservice Inspection and Inservice Testing Program, in accordance with the implementation of previously approved Amendment Nos. 230 and 193 for Limerick Generating Station, Units 1 and 2, respectively, dated July 31, 2018 (Agencywide Documents Access and Management System Accession No. ML18165A162), to adopt Title 10 of the Code of Federal Regulations Section 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors.

A copy of the related Safety Evaluation is also enclosed. Notice of issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

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. 248 to Renewed NPF-39

2. Amendment No. 210 to Renewed NPF-85

3. Safety Evaluation cc: Listserv EXELON GENERATION COMPANY, LLC DOCKET NO. 50-352 LIMERICK GENERATING STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 248 Renewed License No. NPF-39 1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Exelon Generation Company, LLC (Exelon Generation Company), dated November 25, 2019, as supplemented on May 11, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions 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. 248, 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 James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: August 7, 2020 James G.

Danna Digitally signed by James G. Danna Date: 2020.08.07 08:06:19 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 248 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 attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 3

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 a marginal line indicating the area of change.

Remove Page Insert Page 3/4 0-2 3/4 0-2 3/4 0-3 3/4 0-3 (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 Commissions 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. 248, 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. 248

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation.

Failure to perform a Surveillance within the specified Surveillance time interval and allowed extension per Specification 4.0.2, shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance time interval with a maximum allowable extension not to exceed 25%

of the surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified Surveillance time interval and allowed extension per Specification 4.0.2, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Surveillance time interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

4.0.4 Entry into an OPERATIONAL CONDITION or other specified condition in the Applicability of a Limiting Condition for Operation shall only be made when the Limiting Condition for Operations Surveillance Requirements have been met within their Surveillance time interval, except as provided in Specification 4.0.3. When a Limiting Condition for Operation is not met due to its Surveillance Requirements not having been met, entry into an OPERATIONAL CONDITION or other specified condition in the Applicability shall only be made in accordance with Specification 3.0.4.

This provision shall not prevent entry into OPERATIONAL CONDITIONS or other specified conditions in the Applicability that are required to comply with ACTION requirements or that are part of a shutdown of the unit.

4.0.5 Inservice Inspection and Inservice Testing Program Structures, systems, and components (SSCs) within the INSERVICE TESTING PROGRAM shall be tested in accordance with the requirements of 10 CFR 50.55a(f). SSCs within the Inservice Inspection Program shall be inspected in accordance with the requirements of 10 CFR 50.55a(g). The provisions of SR 4.0.2 and SR 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific SR referencing usage of the program.

LIMERICK - UNIT 1 3/4 0-2 Amendment No. 11,38,125,162,169,194, 225,226,248

APPLICABILITY SURVEILLANCE REQUIREMENTS (Continued)

SSCs that have been categorized as Risk-Informed Safety Class (RISC) of RISC-3 in accordance with 10 CFR 50.69, and removed from the INSERVICE TESTING PROGRAM or Inservice Inspection Program in accordance with 10 CFR 50.69(b)(1)(v), are subject to the alternative treatment requirements specified in 10 CFR 50.69(d)(2). The SSCs must continue to meet the acceptance criteria specified in the applicable technical specification surveillance requirements; however, the surveillance frequency is determined as part of the alternative treatment.

LIMERICK - UNIT 1 3/4 0-3 Amendment No. 11,49, 125,171, 194, 225, 248 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 210 Renewed License No. NPF-85 1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Exelon Generation Company, LLC (Exelon Generation Company), dated November 25, 2019, as supplemented on May 11, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions 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. 210, are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: August 7, 2020 James G.

Danna Digitally signed by James G. Danna Date: 2020.08.07 08:07:04 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 210 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 attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 3

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 a marginal line indicating the area of change.

Remove Pages Insert Pages 3/4 0-2 3/4 0-2 3/4 0-3 3/4 0-3

(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 Commissions 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. 210, 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. 210

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance within the specified Surveillance time interval and allowed extension per Specification 4.0.2, shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance time interval with a maximum allowable extension not to exceed 25% of the surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified Surveillance time interval and allowed extension per Specification 4.0.2, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Surveillance time interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

4.0.4 Entry into an OPERATIONAL CONDITION or other specified condition in the Applicability of a Limiting Condition for Operation shall only be made when the Limiting Condition for Operations Surveillance Requirements have been met within their Surveillance time interval, except as provided in Specification 4.0.3. When a Limiting Condition for Operation is not met due to its Surveillance Requirements not having been met, entry into an OPERATIONAL CONDITION or other specified condition in the Applicability shall only be made in accordance with Specification 3.0.4.

This provision shall not prevent entry into OPERATIONAL CONDITIONS or other specified conditions in the Applicability that are required to comply with ACTION requirements or that are part of a shutdown of the unit.

4.0.5 Inservice Inspection and Inservice Testing Program Structures, systems, and components (SSCs) within the INSERVICE TESTING PROGRAM shall be tested in accordance with the requirements of 10 CFR 50.55a(f). SSCs within the Inservice Inspection Program shall be inspected in accordance with the requirements of 10 CFR 50.55a(g). The provisions of SR 4.0.2 and SR 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific SR referencing usage of the program.

LIMERICK - UNIT 2 3/4 0-2 Amendment No. 5, 89, 124, 132, 155, 188, 189, 2 10

APPLICABILITY SURVEILLANCE REQUIREMENTS (Continued)

SSCs that have been categorized as Risk-Informed Safety Class (RISC) of RISC-3 in accordance with 10 CFR 50.69, and removed from the INSERVICE TESTING PROGRAM or Inservice Inspection Program in accordance with 10 CFR 50.69(b)(1)(v), are subject to the alternative treatment requirements specified in 10 CFR 50.69(d)(2). The SSCs must continue to meet the acceptance criteria specified in the applicable technical specification surveillance requirements; however, the surveillance frequency is determined as part of the alternative treatment.

LIMERICK - UNIT 2 3/4 0-3 Amendment No. 12, 89, 133, 155, 188, 210 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 248 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-39 AND AMENDMENT NO. 210 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-85 EXELON GENERATION COMPANY, LLC LIMERICK GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353

1.0 INTRODUCTION

By application dated November 25, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19329A212), Exelon Generation Company, LLC (the licensee) submitted a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC or the Commission) proposing changes to the Technical Specifications (TSs) for Limerick Generating Station (Limerick or LGS), Units 1 and 2.

The supplement dated May 11, 2020, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on January 14, 2020 (85 FR 2161).

The LAR proposes a revision to the TS Surveillance Requirement (SR) 4.0.5, Inservice Inspection and Inservice Testing Program, in accordance with the implementation of previously approved Amendment Nos. 230 and 193 for Limerick Generating Station, Units 1 and 2, respectively, dated July 31, 2018 (ADAMS Accession No. ML18165A162), to adopt Title 10 of the Code of Federal Regulations Section 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors.

2.0 REGULATORY EVALUATION

2.1 Description of Technical Specification Changes In its LAR, the licensee states, in part:

By Reference letter dated July 31, 2018, the NRC issued Amendment Nos. 230 and 193 to Renewed Facility Operating License Nos. NPF-39 and NPF-85 for the LGS, Units 1 and 2, respectively. The amendments added a new license condition to the LGS, Unit 1 and Unit 2 Renewed Facility Operating Licenses to allow the implementation of the risk-informed categorization and treatment of structures, systems or components (SSCs) in accordance with the requirements of 10 CFR 50.69.

Limerick, Units 1 and 2, TS SR 4.0.5, currently states:

4.0.5 Inservice Inspection and Inservice Testing Program The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f). The Inservice Inspection Program is the licensee program that fulfills the requirements of 10 CFR 50.55a(g).

The provisions of SR 4.0.2 and SR 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific SR referencing usage of the program.

The proposed revision to TS SR 4.0.5 would read as follows:

4.0.5 Inservice Inspection and Inservice Testing Program Structures, systems, and components (SSCs) within the INSERVICE TESTING PROGRAM shall be tested in accordance with the requirements of 10 CFR 50.55a(f). SSCs within the Inservice Inspection Program shall be inspected in accordance with the requirements of 10 CFR 50.55a(g). The provisions of SR 4.0.2 and SR 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific SR referencing usage of the program.

SSCs that have been categorized as Risk-Informed Safety Class (RISC) of RISC-3 in accordance with 10 CFR 50.69, and removed from the INSERVICE TESTING or Inservice Inspection Program in accordance with 10 CFR 50.69(b)(1)(v), are subject to the alternative treatment requirements specified in 10 CFR 50.69(d)(2). The SSCs must continue to meet the acceptance criteria specified in the applicable technical specification surveillance requirements; however, the surveillance frequency is determined as part of the alternative treatment.

2.2 Regulatory Requirements The NRC staff considered the following regulatory requirements, guidance, and licensing information during its review of the proposed changes:

The NRC regulations in 10 CFR 50.36(c) require TSs to include the following categories:

(1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) SRs; (4) design features; (5) administrative controls; (6) decommissioning; (7) initial notification; and (8) written reports.

Paragraph 50.36(c)(3) of 10 CFR states, Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

Pursuant to 10 CFR 50.54, Conditions of licenses, the applicable requirements of 10 CFR 50.55a, Codes and standards, are conditions for every nuclear power reactor operating license issued under 10 CFR Part 50. These requirements include inservice testing (IST) of pumps and valves at nuclear power reactors in accordance with the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, Section IST (OM Code), as specified in 10 CFR 50.55a(f), Preservice and inservice testing requirements.

The NRC regulations in 10 CFR 50.55a(f) state, in part:

Systems and components of boiling and pressurized water-cooled nuclear power reactors must meet the requirements for preservice and inservice testing (referred to in this paragraph (f) collectively as inservice testing) of the ASME BPV [Boiler and Pressure Vessel] Code and ASME OM Code as specified in this paragraph (f). Each operating license for a boiling or pressurized water-cooled nuclear facility is subject to the following conditions The ASME OM Code is a consensus standard that is incorporated by reference in 10 CFR 50.55a with conditions. During the incorporation process, for each edition and addenda of the ASME OM Code, the NRC staff reviews the ASME OM Code requirements for technical sufficiency to determine whether the ASME OM Code IST program requirements are suitable for incorporation into the NRCs rules with conditions, as applicable. The current ASME OM Code of record for Limerick, Units 1 and 2, is the 2012 Edition of the ASME OM Code, as incorporated by reference in 10 CFR 50.55a.

The regulations in 10 CFR 50.55(a)(f)(5)(ii), IST Program update: Conflicting IST Code requirements with technical specifications, state, in part:

If a revised inservice test program for a facility conflicts with the technical specifications for the facility, the licensee must apply to the Commission for amendment of the technical specifications to conform the technical specifications to the revised program.

3.0 TECHNICAL EVALUATION

In describing the proposed TS changes, the licensee states, in part:

As noted above, LGS has been given approval by the NRC to implement 10 CFR 50.69 at the station. SSCs that have been categorized as RISC-3 in accordance with 10 CFR 50.69 may be removed from the special treatment requirements of 10 CFR 50.55a(f) and (g), and instead, be subject to alternative treatment requirements of 10 CFR 50.69(d)(2). However, the LGS, Unit 1 and Unit 2 TS contain surveillance requirements applicable to SSCs that are either currently categorized as RISC-3 or have the possibility of being categorized as RISC-3 in the future. These surveillances require testing pursuant to TS 4.0.5.

LGS TS 4.0.5 states that the INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f) and the Inservice Inspection Program is the licensee program that fulfills the requirements of 10 CFR 50.55a(g).

The licensee further states, in part:

The proposed addition to TS 4.0.5 provides the clarification that, even though the SSCs are subject to the acceptance criteria in the applicable TS surveillance requirements, if they have been categorized as RISC-3 in accordance with 10 CFR 50.69, then they are subject to testing, including the frequency of testing, and inspection that fulfils the alternative treatment requirements of 10 CFR 50.69(d)(2) rather than the requirements of 10 CFR 50.55a(f) or (g).

The proposed changes do not involve any physical changes to plant SSCs or the way SSCs are operated, controlled, maintained, or modified. The proposed changes do not involve a change to any safety limits, limiting safety system settings, limiting control settings, limiting conditions for operation, design features, or administrative controls required by 10 CFR 50.36.

In its LAR, the licensee proposes to clarify TS 4.0.5 requirements to reflect the allowance provided in 10 CFR 50.69(b)(1)(v) to perform alternative treatment of SSCs that have been categorized as RISC-3 in accordance with the requirements of 10 CFR 50.69 in lieu of performing inspection and testing in accordance with the requirements of 10 CFR 50.55a(f) and (g).

By email dated May 11, 2020 (ADAMS Accession No. ML20132A082), the licensee clarified its application in response to a question from the NRC staff. The staff requested the licensee to explain if the proposed changes to TS SR 4.0.5 are applicable to the snubber examination and testing requirements provided in TS Administrative Control section 6.8.4.k, Snubber Program.

The licensees response to the request for additional information stated that the proposed changes in TS SR4.0.5 are not applicable to the snubber examination and testing as specified in TS 6.8.4.k. Therefore, Limerick, Units 1 and 2, will continue implement the snubber examination and testing requirement as specified in TS 6.8.4.k.

The licensee considers the proposed TS changes to be administrative in nature with no impact to the physical configuration or function of plant SSCs or the way SSCs are operated, maintained, or modified. The licensee states that only a clarification is being provided in TS 4.0.5 in that SSCs categorized as RISC-3 are tested or inspected in accordance with the alternative treatment requirements of 10 CFR 50.69(d)(2). The licensee asserts that the proposed changes do not impact the initiators or assumptions of analyzed events, nor do they impact mitigation of accidents or transient events.

In Section III.4.10.2, Section 50.36 Technical Specifications, of a Federal Register notice, dated November 22, 2004 (69 FR 68008, 68028-68029), the Commission stated that the 10 CFR 50.69 rule does not include 10 CFR 50.36 in the list of special treatment requirements that may be replaced by the alternative 10 CFR 50.69 requirements for RISC-3 and RISC-4 SSCs when implementing a 10 CFR 50.69 license amendment. As a result, the NRC staff does not consider the TSs (including the associated Technical Requirements Manual) to be part of the 10 CFR 50.69 rule. Therefore, licensees should continue to follow their TSs (including the Technical Requirements Manual, as applicable) when implementing 10 CFR 50.69.

3.1 Technical Conclusion The NRC staff finds that the proposed changes to TS 4.0.5 for Limerick, Units 1 and 2, are consistent with the approved implementation of the 10 CFR 50.69 requirements. The proposed changes specify that RISC-3 SSCs must continue to meet the acceptance criteria specified in the applicable TS SR requirements; however, the surveillance frequency will be determined as part of the alternative treatment developed in accordance with 10 CFR 50.69. The proposed changes do not involve a change to any safety limits, limiting safety system settings, limiting control settings, limiting conditions for operation, design features, or administrative controls required by 10 CFR 50.36 and, therefore, the proposed changes do not impact the initiators or assumptions of analyzed events, nor do they impact mitigation of accidents or transient events.

Based on these considerations, the NRC staff concludes the proposed changes to TS 4.0.5 are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the NRC staff notified the Pennsylvania State official on May 14, 2020, of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves 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, which was published in the Federal Register on January 14, 2020 (85 FR 2161), that the amendment involves no significant hazards consideration, and there has been no public comment on such finding.

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 amendment.

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 Commissions 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: G Bedi Date: August 7, 2020

ML20160A459 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC NAME VSreenivas LRonewicz VCusumano DATE 6/09/2020 6/09/2020 5/19/2020 OFFICE NRR/DRA/APLA/BC NRR/DNRL/NPHP/BC NRR/DEX/EMIB/BC NAME RPascarelli MMitchell ABuford DATE 5/27/2020 5/14/2020 5/26/2020 OFFICE OGC - NLO NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME STurk JDanna VSreenivas DATE 6/26/2020 8/07/2020 8/07/2020