ML21138A801

Submittal of Rev. 20 to Updated Final Safety Analysis Report

ML21138A801
Person / Time
Site:	Limerick
Issue date:	04/29/2021
From:	David Helker Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
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References
Download: ML21138A801 (3)

Text

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~*"' Exelon GenerationGl Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.71 (e)(4) 10 CFR 54.37(b) 10 CFR 50.4(b)(6)

April 29, 2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRG Docket Nos. 50-352 and 50-353

Subject:

Amended Update to Updated Final Safety Analysis Report (UFSAR),

Revision 20

Reference:

Letter from David P. Helker (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Submittal of Updated Final Safety Analysis Report, Revision 20 and UFSAR Reference Drawings," dated September 19, 2020 By letter dated September 19, 2020 (Reference), Exelon Generation Company, LLC (Exelon) submitted Revision 20 of the Limerick Generating Station (LGS), Units 1 and 2, Updated Final Safety Analysis Report (UFSAR) in accordance with the requirements of 10 CFR 50.71(e)(4), 10 CFR 54.37(b), and 10 CFR 50.4(b)(6). This subject revision of the LGS UFSAR was submitted in entirety in electronic format on compact disk (CD).

Subsequently, Exelon learned that certain electronic files contained on the CD (in particular, those files related to Appendix 3B) had been marked as proprietary. Exelon reviewed the LGS UFSAR revision history and determined that the applicable files are legacy/historical files that were submitted in conjunction with Revision O of the UFSAR as docketed in a letter dated August 24, 1990 (Accession No. 9008280047). The August 24, 1990, letter requested that files contained in Appendix 3B be withheld from public disclosure in accordance with 10 CFR 2.790(a)(4). The August 24, 1990, letter specifically referenced a June 30, 1982, letter that had been docketed (Accession No. 8207070390) which contained an affidavit to support withholding the information from public disclosure. Based on our review of the revision history, it appears that the files in Appendix 3B had likely not been revised since the issuance of Revision O of the LGS UFSAR. Therefore, the affidavit still supports maintaining the information in Appendix 3B as proprietary.

To further facilitate the submittal of future revisions of the LGS UFSAR and to avoid the potential need to provide an affidavit with each update, the Appendix 3B information will now be "incorporated by reference" into the UFSAR. The process of incorporating information by reference is a recognized and acceptable practice as discussed in NEI 98-03, Revision 1, "Guidelines for Updating Final Safety Analysis Reports," which has been endorsed by the U.S.

Nuclear Regulatory Commission (NRG) in Regulatory Guide 1.181, "Content of the Updated Final

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U.S. Nuclear Regulatory Commission Submittal of Amended LGS UFSAR Revision 20 NRG Docket Nos. 50-352 and 50-353 April 29, 2021 Page2 Safety Analysis Report in Accordance with 10 CFR 50. 71(e)." As such, future updates of the LGS UFSAR will likely not include the Appendix 3B electronic files unless these files have been updated per Exelon's administrative processes for controlling UFSAR changes and updates. In the event that any Appendix 3B files are in need of revision in the future, then Exelon will submit the changes in accordance with the requirements of 10 CFR 50.71 (e) and a new affidavit supporting withholding any information would be considered at that time.

Accordingly, Exelon is amending the submittal of Revision 20 of the LGS UFSAR and is submitting in electronic format on the attached digital video disk (DVD) an entire updated copy of Revision 20 of the LGS UFSAR along with the supporting reference drawings, except for the affected Appendix 3B files. There have been no additional UFSAR changes processed and the description of changes described in the Reference 1 submittal remains the same. The attached DVD constitutes a total replacement copy and supersedes the CD submitted in the Reference 1 letter.

In addition, Exelon is also requesting that in the event any Appendix 3B files might be available as part of previous revisions of the LGS UFSAR (e.g., Revision 19), then this information be withheld for the reason as discussed above.

As required by 10CFR50.71(e)(2)(i), I certify that to the best of my knowledge, the information contained in the attachment to this letter accurately reflects information and analyses submitted to the NRG, or prepared pursuant to NRG requirements as described above.

If you have any questions or require further information, please contact Richard Gropp at (610) 765-5557.

Respectfully,

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• David P. Helker Sr. Manager, Licensing Exelon Generation Company, LLC

Attachment:

Limerick Generating Station, Units 1 and 2, Amended Update to Updated Final Safety Analysis Report (UFSAR), Revision 20 (DVD) cc: w/ Attachment Regional Administrator, Region I, USNRC USNRC Senior Resident Inspector, Limerick Generating Station USNRC Senior Project Manager NRR, Limerick Generating Station W. DeHaas, Commonwealth of Pennsylvania, Bureau of Radiation Protection

Attachment Limerick Generating Station, Units 1 and 2 Amended Update to Updated Final Safety Analysis Report (UFSAR), Revision 20 Digital Video Disk (DVD}

CAUTION Do not bend or fold Avoid exposure to all magnetic fields