ML20239A725

Issuance of Amendment Nos. 249 and 211 Adopt TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities

ML20239A725
Person / Time
Site:	Limerick
Issue date:	11/30/2020
From:	V Sreenivas Plant Licensing Branch 1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Sreenivas V, NRR/DORL/LPLI, 415-2597
References
EPID L-2019-LLA-0047
Download: ML20239A725 (16)

Text

November 30, 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. 249 AND 211 RE: ADOPT TSTF 484, REVISION 0, USE OF TS 3.10.1 FOR SCRAM TIME TESTING ACTIVITIES (EPID L-2019-LLA-0047)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 249 and 211 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 March 18, 2020.

The amendments revise Technical Specification (TS) 3/4.10.8, Inservice Leak and Hydrostatic Testing, by adopting Technical Specification Task Force (TSTF) Traveler TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities. Specifically, Limiting Condition for Operation 3.10.8 is expanded in scope to include provisions for temperature excursions greater than 212 degrees Fahrenheit (°F) as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Operational Condition 4.

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. 249 to Renewed NPF-39

2. Amendment No. 211 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. 249 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 March 18, 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. 249, 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.

Enclosure 1

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

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by James James G. G. Danna Date: 2020.11.30 Danna 13:59:25 -05'00' 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: November 30, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 249 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 page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the areas of change.

Remove Page Insert Page 3/4 10-8 3/4 10-8

(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. 249, 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. 249

SPECIAL TEST EXCEPTIONS 3/4.10.8 INSERVICE LEAK AND HYDROSTATIC TESTING LIMITING CONDITIONS FOR OPERATION 3.10.8 When conducting inservice leak or hydrostatic testing, the average reactor coolant temperature specified in Table 1.2 for OPERATIONAL CONDITION 4 may be increased to greater than 200°F, and operation considered not to be in OPERATIONAL CONDITION 3:

For performance of an inservice leak or hydrostatic test, As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, provided the following OPERATIONAL CONDITION 3 Specifications are met:

a. 3.3.2 ISOLATION ACTUATION INSTRUMENTATION, Functions 7.a, 7.c.1, 7.c.2 and 7.d of Table 3.3.2-1;

b. 3.6.5.1.1 REACTOR ENCLOSURE SECONDARY CONTAINMENT INTEGRITY;

c. 3.6.5.1.2 REFUELING AREA SECONDARY CONTAINMENT INTEGRITY;

d. 3.6.5.2.1 REACTOR ENCLOSURE SECONDARY CONTAINMENT AUTOMATIC ISOLATION VALVES;

e. 3.6.5.2.2 REFUELING AREA SECONDARY CONTAINMENT AUTOMATIC ISOLATION VALVES; and

f. 3.6.5.3 STANDBY GAS TREATMENT SYSTEM.

APPLICABILITY: OPERATIONAL CONDITION 4, with average reactor coolant temperature greater than 200°F.

ACTION:

With the requirements of the above Specifications not satisfied:

1. Immediately enter the applicable (OPERATIONAL CONDITION 3) action for the affected Specification; or

2. Immediately suspend activities that could increase the average reactor coolant temperature or pressure and reduce the average reactor coolant temperature to 200°F or less within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.10.8 Verify applicable OPERATIONAL CONDITION 3 surveillances for the Specifications listed in 3.10.8 are met.

LIMERICK - UNIT 1 3/4 10-8 Amendment No. 133, 249

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 211 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 March 18, 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. 211, 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.

Enclosure 2

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

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by James James G. G. Danna Date: 2020.11.30 Danna 14:00:28 -05'00' 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: November 30, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 211 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 page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the areas of change.

Remove Page Insert Page 3/4 10-9 3/4 10-9

(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. 211, 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. 211

SPECIAL TEST EXCEPTIONS 3/4.10.8 INSERVICE LEAK AND HYDROSTATIC TESTING LIMITING CONDITION FOR OPERATION 3.10.8 When conducting inservice leak or hydrostatic testing, the average reactor coolant temperature specified in Table 1.2 for OPERATIONAL CONDITION 4 may be increased to greater than 200°F, and operation considered not to be in OPERATIONAL CONDITION 3:

For performance of an inservice leak or hydrostatic test, As a consequence of maintaining adequate pressure for an inservice leak or hydrostatic test, or As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with an inservice leak or hydrostatic test, provided the following OPERATIONAL CONDITION 3 Specifications are met:

a. 3.3.2 ISOLATION ACTUATION INSTRUMENTATION, Functions 7.a, 7.c.1, 7.c.2 and 7.d of Table 3.3.2-1;

b. 3.6.5.1.1 REACTOR ENCLOSURE SECONDARY CONTAINMENT INTEGRITY;

c. 3.6.5.1.2 REFUELING AREA SECONDARY CONTAINMENT INTEGRITY;

d. 3.6.5.2.1 REACTOR ENCLOSURE SECONDARY CONTAINMENT AUTOMATIC ISOLATION VALVES;

e. 3.6.5.2.2 REFUELING AREA SECONDARY CONTAINMENT AUTOMATIC ISOLATION VALVES; and

f. 3.6.5.3 STANDBY GAS TREATMENT SYSTEM.

APPLICABILITY: OPERATIONAL CONDITION 4, with average reactor coolant temperature greater than 200°F.

ACTION:

With the requirements of the above Specifications not satisfied:

1. Immediately enter the applicable (OPERATIONAL CONDITION 3) action for the affected Specification; or

2. Immediately suspend activities that could increase the average reactor coolant temperature or pressure and reduce the average reactor coolant temperature to 200°F or less within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENTS _____

4.10.8 Verify applicable OPERATIONAL CONDITION 3 surveillances for the Specifications listed in 3.10.8 are met.

LIMERICK - UNIT 2 3/4 10-9 Amendment No. 95, 211

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 249 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-39 AND AMENDMENT NO. 211 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 March 18, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20078G307), Exelon Generation Company, LLC (the licensee) submitted a license amendment request to the U.S. Nuclear Regulatory Commission (NRC, the Commission) proposing changes to the Technical Specifications (TSs) for Limerick Generating Station (Limerick), Units 1 and 2.

Specifically, the license amendment request proposes to revise TS 3/4.10.8, Inservice Leak and Hydrostatic Testing, Limiting Condition for Operation (LCO) 3.10.8 to expand its scope to include provisions for temperature excursions greater than 212 degrees Fahrenheit (°F) as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Operational Condition 4. This change is consistent with NRC-approved Technical Specification Task Force (TSTF) Traveler, TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities (ADAMS Accession No. ML052930102)

(hereafter TSTF-484). The availability of TSTF-484 was announced in the Federal Register on October 27, 2006 (71 FR 63050), as part of the consolidated line item improvement process.

2.0 REGULATORY EVALUATION

2.1 Inservice Leak and Hydrostatic Testing The reactor coolant system (RCS) serves as a pressure boundary and also serves to provide a flow path for the circulation of coolant past the fuel. In order to maintain RCS integrity,Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code requires periodic hydrostatic and leakage testing. Hydrostatic tests are required to be performed once every 10 years, and leakage tests are required to be performed each refueling outage. Appendix G, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50 Enclosure 3

states that pressure tests and leak tests of the reactor vessel that are required by Section XI of the ASME BPV Code must be completed before the core is critical.

TSTF-484 made changes to NUREG-1433, General Electric Plants (BWR/4), Revision 3, Standard Technical Specifications (STS) and NUREG-1434, General Electric Plants (BWR/6),

Revision 3, and was approved by the NRC for plant-specific adoption on October 12, 2006 (ADAMS Accession No. ML062760109). The use of TS 3.10.1 for scram time testing activities in TSTF-484 modifies LCO 3.10.1 to allow a licensee to implement LCO 3.10.1 while hydrostatic and leakage testing is being conducted, should average reactor coolant temperature exceed 200 °F during testing. This modification does not alter current requirements for hydrostatic and leakage testing as required by Appendix G to 10 CFR Part 50. The TSTF-484 changes were incorporated into Revision 4 of the STS for NUREG-1433 and NUREG-1434. The licensee proposed adoption of the TSTF-484 changes into the Limerick, Units 1 and 2, TSs and listed the variations between the Limerick TSs and STS in NUREG-1433 and NUREG-1434.

2.2 Control Rod Scram Time Testing Control rods function to control reactor power level and to provide adequate excess negative reactivity to shut down the reactor from any normal operating or accident condition at any time during core life. The control rods are scrammed by using hydraulic pressure exerted by the control rod drive system. Criterion 10, Reactor design, of Appendix A to 10 CFR Part 50 states that the reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences. The scram reactivity used in design-basis accidents and transient analyses is based on an assumed control rod scram time.

The TSTF-484 changes regarding scram time testing activities were incorporated into NUREG-1433, Revision 4, and NUREG-1434, Revision 4. LCO 3.10.1 was modified to allow Surveillance Requirements (SRs) 3.1.4.1 and 3.1.4.4 to be conducted in Mode 4 with average reactor coolant temperature greater than 200 °F. SR 3.1.4.1 requires scram time testing to be conducted following a shutdown greater than 120 days, while SR 3.1.4.4 requires scram time testing to be conducted following work on the control rod drive system or following fuel movement within the affected core cell. Both SRs must be performed at reactor steam dome pressure greater than or equal to 800 pounds per square inch gauge (psig) and prior to exceeding 40 percent rated thermal power. Scram time testing would be performed in accordance with LCO 3.10.4, Single Control Rod Withdrawal - Cold Shutdown. This modification to LCO 3.10.1 did not alter the means of compliance with Criterion 10 of Appendix A to 10 CFR Part 50.

3.0 TECHNICAL EVALUATION

The existing provisions of LCO 3.10.8 in the Limerick TSs allow for hydrostatic and leakage testing to be conducted while in Operational Condition 4 with average reactor coolant temperature up to 212°F, while imposing Operational Condition 3 secondary containment requirements. Under the existing provision, LCO 3.10.8 would have to be implemented prior to hydrostatic and leakage testing. As a result, if LCO 3.10.8 was not implemented prior to hydrostatic and leakage testing, hydrostatic and leakage testing would have to be terminated if average reactor coolant temperature exceeded 212 °F during the conduct of the hydrostatic and leakage test.

TSTF-484 modifies LCO 3.10.1 (Limerick, Units 1 and 2, LCO 3.10.8) to allow a licensee to implement LCO 3.10.1 while hydrostatic and leakage testing is being conducted, should average reactor coolant temperature exceed 212 °F during testing. The modification will allow completion of testing without the potential for interrupting the test in order to reduce reactor vessel pressure, cool the RCS, and restart the test below 200 °F. Since current LCO 3.10.8 allows testing to be conducted while in Operational Condition 4 with average reactor coolant temperature greater than 212 °F, the proposed change does not introduce any new operational conditions beyond those currently allowed in TSTF-484.

SRs 3.1.4.1 and 3.1.4.4 require that control rod scram time be tested at reactor steam dome pressure greater than or equal to 950 psig and before exceeding 40 percent rated thermal power. Performance of control rod scram time testing is typically scheduled concurrent with inservice leak or hydrostatic testing while the RCS is pressurized. Because of the number of control rods that must be tested, it is possible for the inservice leak or hydrostatic test to be completed prior to completing the scram time test. Under existing provisions, if scram time testing can not be completed during the LCO 3.10.8 inservice leak or hydrostatic test, scram time testing must be suspended. Additionally, if LCO 3.10.8 is not implemented and average reactor coolant temperature exceeds 212 °F while performing the scram time test, scram time testing must also be suspended. In both situations, scram time testing is resumed during startup and is completed prior to exceeding 40 percent rated thermal power.

TSTF-484 modifies LCO 3.10.1 to allow a licensee to complete scram time testing initiated during inservice leak or hydrostatic testing. As stated earlier, since the current LCO 3.10.8 allows testing to be conducted while in Operational Condition 4 with average reactor coolant temperature greater than 212 °F, the proposed change does not introduce any new operational conditions beyond those currently allowed. Completion of scram time testing prior to reactor criticality and power operations results in a more conservative operating philosophy with attendant potential safety benefits.

It is acceptable to perform other testing concurrent with the inservice leak or hydrostatic test, provided that this testing can be performed safely and does not interfere with the leak or hydrostatic test. However, it is not permissible to remain in TS 3.10.8 solely to complete such testing following the completion of inservice leak or hydrostatic testing and scram time testing.

Since the tests are performed with the reactor pressure vessel nearly water solid, at low decay heat values, and near Operational Condition 4 conditions, the stored energy in the reactor core will be very low. Small leaks from the RCS would be detected by inspections before a significant loss of inventory occurred. In addition, two low-pressure emergency core cooling system (ECCS) injection/spray subsystems are required to be operable in Mode 4 by TS 3.5.2, ECCS-Shutdown. In the event of a large RCS leak, the reactor pressure vessel would rapidly depressurize and allow operation of the low pressure ECCS. The capability of the low pressure ECCS would be adequate to maintain the fuel covered under the low decay heat conditions during these tests. Also, LCO 3.10.8 requires that secondary containment and standby gas treatment system be operable and capable of handling any airborne radioactivity or steam leaks that may occur during performance of testing.

The protection provided by the normally required Operational Condition 4 applicable LCOs, in addition to the secondary containment requirements required to be met by LCO 3.10.8, minimizes potential consequences in the event of any postulated abnormal event during testing.

In addition, the requested modification to LCO 3.10.8 does not create any new modes of

operation or operating conditions that are not currently allowed. Therefore, the staff finds the proposed change acceptable.

Based on the above, the changes to the Limerick, Units 1 and 2, TSs are acceptable for the same reasons they were acceptable in NRC-approved TSTF-484 and in incorporation of those changes into NUREG-1433, Revision 4, and NUREG-1434, Revision 4.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the NRC staff notified the Pennsylvania State official on August 18, 2020, of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change 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, which was published in the Federal Register on April 21, 2020 (85 FR 22185-22186), that the amendments involve 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 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 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: A. Russell Date: November 30, 2020

ML20239A725 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC NAME VSreenivas LRonewicz VCusumano DATE 08/31/2020 08/31/2020 08/05/2020 OFFICE NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME JDanna VSreenivas DATE 11/30/2020 11/30/2020