ML22348A176
| ML22348A176 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/07/2023 |
| From: | V Sreenivas Plant Licensing Branch 1 |
| To: | Rhoades D Constellation Energy Generation |
| Sreenivas V, NRR/DORL/LPLI, 415-2597 | |
| References | |
| EPID L-2022-LLA-0035 | |
| Download: ML22348A176 (22) | |
Text
March 7, 2023 Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 260 AND 222, REGARDING TECHNICAL SPECIFICATION 3.3.7.4, REMOTE SHUTDOWN SYSTEM INSTRUMENTATION AND CONTROLS, AND AN ADMINISTRATIVE CORRECTION FOR LICENSING PAGE (EPID L-2022-LLA-0035)
Dear Mr. Rhoades:
The U.S. Nuclear Regulatory Commission (NRC or the Commission) has issued the enclosed Amendment No. 260 to Renewed Facility Operating License No. NPF-39 and Amendment No. 222 to Renewed Facility Operating License No. NPF-85 for the Limerick Generating Station, Units 1 and 2, respectively. The amendments are in response to your application dated February 24, 2022 (Agencywide Documents Access and Management System Accession (ADAMS) No. ML22055A601).
The amendments revise the technical specifications (TSs) to increase the allowed outage time for inoperable remote shutdown system components to a time that is more consistent with their safety significance and delete TS Table 3.3.7.4-1, Remote Shutdown System Instrumentation and Controls, to be relocated to the technical requirements manual. Limerick Generating Station, Unit 1, Amendment No. 260 also replaces licensing page number 3 to Amendment No. 258 issued on January 3, 2023, to its originally issued page number 3 to Amendment No. 255 issued on April 29, 2022. The NRC staff considers this error as administrative in nature.
D. Rhoades A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly 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. 260 to NPF-39
- 2. Amendment No. 222 to NPF-85
- 3. Safety Evaluation cc: Listserv CONSTELLATION ENERGY GENERATION, LLC DOCKET NO. 50-352 LIMERICK GENERATING STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 260 Renewed License No. NPF-39 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Constellation Energy Generation, LLC dated February 24, 2022, 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 renewed 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. 260, are hereby incorporated into this renewed license. Constellation Energy Generation, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
3.
This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Hipólito J. González, 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: March 7, 2023 Hipolito J.
Gonzalez Digitally signed by Hipolito J. Gonzalez Date: 2023.03.07 15:39:48 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 260 LIMERICK GENERATING STATION, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. NPF-39 DOCKET NO. 50-352 Replace the following pages of the Renewed Facility Operating License with the attached revised pages. The revised pages are identified by amendment number and contains a marginal line indicating the area of change.
Remove Page Insert Page 3
3 4
4 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Page Insert Page 3/4 3-76 3/4 3-76 3/4 3-77 3/4 3-77 3/4 3-78 3/4 3-79 3/4 3-80 3/4 3-81 3/4 3-82 (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 Constellation Energy Generation, LLC 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.
Renewed License No. NPF-39 Amendment No. 260 (2)
Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 260, are hereby incorporated into this renewed license. Constellation Energy Generation, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
Fire Protection (Section 9.5, SSER-2, -4)*
Constellation Energy Generation, LLC shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report for the facility, and as approved in the NRC Safety Evaluation Report dated August 1983 through Supplement 9, dated August 1989, and Safety Evaluation dated November 20, 1995, subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
The Information contained on FOL pages 5 and 6 were intentionally omitted.
- The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.
Renewed License No. NPF-39 Amendment No. 260
INSTRUMENTATION REMOTE SHUTDOWN SYSTEM LIMITING CONDITION FOR OPERATION 3.3.7.4 The remote shutdown system functions shall be OPERABLE.
APPLICABILITY:
OPERATIONAL CONDITIONS 1 and 2.
ACTION**:
a.
With one or more of the required functions inoperable, restore the inoperable function(s) to OPERABLE status within 30 days or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
SURVEILLANCE REQUIREMENTS 4.3.7.4.1 Each normally energized required instrumentation channel shall be demonstrated OPERABLE by performance of a CHANNEL CHECK* at the frequency specified in the Surveillance Frequency Control Program.
4.3.7.4.2 Each required control circuit and transfer switch shall be demonstrated OPERABLE by verifying its capability to perform its intended function in accordance with the Surveillance Frequency Control Program.
4.3.7.4.3 Each required instrumentation channel shall be demonstrated OPERABLE by performance of a CHANNEL CALIBRATION at the frequency specified in the Surveillance Frequency Control Program.
Control is not required to be transferred to perform the CHANNEL CHECK.
- NOTE: Separate ACTION entry is allowed for each function.
LIMERICK - UNIT 1 3/4 3-76 Amendment No. 71, 169, 186, 260111
TABLE 3.3.7.4-1 REMOTE SHUTDOWN SYSTEM INSTRUMENTATION AND CONTROLS MINIMUM INSTRUMENTS INSTRUMENT OPERABLE THE INFORMATION FROM THIS TECHNICAL SPECIFICATIONS SECTION HAS BEEN RELOCATED TO THE TRM. TECHNICAL SPECIFICATIONS PAGES 3/4 3-78 THROUGH 3/4 3-82 OF THIS SECTION HAVE BEEN INTENTIONALLY OMITTED.
LIMERICK - UNIT 1 3/4 3-77 Amendment No. 45 260 CONSTELLATION ENERGY GENERATION, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 222 Renewed License No. NPF-85 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Constellation Energy Generation, LLC dated February 24, 2022, 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. 222, are hereby incorporated into this renewed license. Constellation Energy Generation, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
3.
This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Hipólito J. González, 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: March 7, 2023 Hipolito J.
Gonzalez Digitally signed by Hipolito J. Gonzalez Date: 2023.03.07 15:38:54 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 222 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 marginal lines indicating the areas of change.
Remove Page Insert Page 3/4 3-76 3/4 3-76 3/4 3-77 3/4 3-77 3/4 3-78 3/4 3-79 3/4 3-80 3/4 3-81 3/4 3-82 (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 Constellation Energy Generation, LLC 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. 222, are hereby incorporated into this renewed license. Constellation Energy Generation, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
Renewed License No. NPF-85 Amendment No. 222
INSTRUMENTATION REMOTE SHUTDOWN SYSTEM LIMITING CONDITION FOR OPERATION 3.3.7.4 The remote shutdown system functions shall be OPERABLE.
APPLICABILITY: OPERATIONAL CONDITIONS 1 and 2.
ACTION**:
a.
With one or more of the required functions inoperable, restore the inoperable function(s) to OPERABLE status within 30 days or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
SURVEILLANCE REQUIREMENTS 4.3.7.4.1 Each normally energized required instrumentation channel shall be demonstrated OPERABLE by performance of a CHANNEL CHECK* at the frequency specified in the Surveillance Frequency Control Program.
4.3.7.4.2 Each required control circuit and transfer switch shall be demonstrated OPERABLE by verifying its capability to perform its intended function in accordance with the Surveillance Frequency Control Program.
4.3.7.4.3 Each required instrumentation channel shall be demonstrated OPERABLE by performance of a CHANNEL CALIBRATION at the frequency specified in the Surveillance Frequency Control Program.
Control is not required to be transferred to perform the CHANNEL CHECK.
- NOTE: Separate ACTION entry is allowed for each function.
LIMERICK - UNIT 2 3/4 3-76 Amendment No. 34, 132, 147, 111
TABLE 3.3.7.4-1 REMOTE SHUTDOWN SYSTEM INSTRUMENTATION AND CONTROLS MINIMUM INSTRUMENTS INSTRUMENT OPERABLE THE INFORMATION FROM THIS TECHNICAL SPECIFICATIONS SECTION HAS BEEN RELOCATED TO THE TRM. TECHNICAL SPECIFICATIONS PAGES 3/4 3-78 THROUGH 3/4 3-82 OF THIS SECTION HAVE BEEN INTENTIONALLY OMITTED.
LIMERICK - UNIT 2 3/4 3-77
$PHQGPHQW1R
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 260 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-39 AND AMENDMENT NO. 222 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-85 CONSTELLATION ENERGY GENERATION, LLC LIMERICK GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353
1.0 INTRODUCTION
By letter dated February 24, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22055A601), Constellation Energy Generation, LLC (the licensee) requested U.S. Nuclear Regulatory Commission (NRC, the Commission) approval for a license amendment request (LAR) to revise the Limerick Generating Station (Limerick), Units 1 and 2, Technical Specifications (TSs). The LAR proposes to revise Limerick TS 3.3.7.4, Remote Shutdown System Instrumentation and Controls, to make it consistent with TS 3.3.3.2, Remote Shutdown System, in NUREG-1433, Revision 5.0, Standard Technical Specifications -
General Electric BWR/4 Plants, Volume 1, Specifications (ML21272A357). The change would increase the allowed outage time for inoperable remote shutdown system components from 7 days to 30 days. Also, the amendment would delete TS Table 3.3.7.4-1, Remote Shutdown System Instrumentation and Controls, and relocate its requirements to the Limerick Technical Requirements Manual (TRM) where they would be directly controlled by the licensee.
2.0 REGULATORY EVALUATION
2.1 Description of the Remote Shutdown System The remote shutdown system (RSS) provides the means for achieving and maintaining safe shutdown conditions from outside the main control room in the unlikely event that the main control room becomes uninhabitable. The primary control station for the RSS is the remote shutdown panel (RSP). In the event of a failure at the RSP, sufficient redundant safety grade instrumentation and controls are available remotely from both the main control room and the RSP to ensure that safe shutdown of the reactor can be achieved in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, Appendix A, General Design Criteria [GDC]
for Nuclear Power Plants, Criterion 19, Control room (GDC 19).
2.2.1 Description of the Proposed Changes 1.
Revise the TS 3.3.7.4 Limiting Condition for Operation (LCO) to state that the remote shutdown system functions shall be OPERABLE and delete its reference to TS Table 3.3.7.4-1 as listing the specific instrumentation and controls for the remote shutdown system. This proposed change would relocate the information in that table to licensee-controlled documents.
2.
Revise TS 3.3.7.4, ACTION a. to delete the reference to monitoring instrumentation channels as shown in the associated TS Table 3.3.7.4-1. The ACTION would be simplified to state the entry condition for the action as one or more of the required functions inoperable. In addition, the proposed change would add a note to permit separate condition entry for each function.
3.
Revise TS 3.3.7.4, ACTION a. to change the allowed outage time from 7 days to 30 days.
4.
Delete TS 3.3.7.4, ACTION b.
5.
Delete Table 3.3.7.4-1 and relocate the remote shutdown system equipment information to the Limerick TRM.
6.
Revise Surveillance Requirement (SR) 4.3.7.4.1 and add SR 4.3.7.4.3 to:
a) Delete reference to TS Table 4.3.7.4-1 which is being deleted, b) Relocate channel calibration to a new SR 4.3.7.4.3, c) Require the channel check only for normally energized required remote shutdown system instrumentation channels, and d) Replace the with a.
7.
Revise SR 4.3.7.4.2 by replacing, Each of the above remote shutdown switch(es) and control circuits with Each required control circuit and transfer switch and by replacing function(s) with function.
2.3 Regulatory Requirements Section 50.36, Technical specifications, of 10 CFR identifies the requirements for the TS categories for operating facilities. Of these requirements, the following two are applicable to this review:
10 CFR 50.36(c)(2), which states, in part:
Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.
10 CFR 50.36(c)(3), which 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.
GDC 19 is also applicable to this review and it states, in part:
Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures.
2.4 Regulatory Guidance The regulatory guidance applicable to this review is NUREG-1433, Revision 5.0, Volume 1.
3.0 TECHNICAL EVALUATION
3.1 Revision to the TS 3.3.7.4 LCO for the Remote Shutdown System GDC 19 requires that the licensee provide remote shutdown capability. The remote shutdown system functions are described in the Limerick Updated Final Safety Analysis Report (ML18285A632).
The licensee requested a revision to the Limerick TS 3.3.7.4 LCO to state that the remote shutdown system functions shall be operable. This revision would delete reference to instrumentation as shown in the associated TS Table 3.3.7.4-1. In section 3.3.7.4 of the current Limerick TSs, table 3.3.7.4-1 lists the specific instrumentation and controls for the remote shutdown system. The proposed change would relocate these requirements to licensee-controlled documents.
The definition of operable in Limerick TS 1.25 states that a system shall be operable or have operability when it is capable of performing its specified function(s) and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system to perform its function(s) are also capable of performing their related support function(s). This definition provides adequate guidance for determining what instrumentation and controls are necessary for a particular remote shutdown function. The ability to transfer the control of a function from the main control room to the auxiliary shutdown panel is a required support function by the TS definition of operable. Therefore, listing specific instrumentation and controls in the TSs is unnecessary and may lead to needless expenditure of licensee and NRC resources in processing license amendments to revise the remote shutdown system details in TS table 3.3.7.4-1. These details are not necessary to describe the actual regulatory requirements.
Moreover, SR 4.3.7.4.2 would still require the local panel transfer function to be tested, which is sufficient to ensure that the system will be operable. Relocation of the list of variables to the TRM is acceptable because the TRM is consistent with the design basis as described in the Limerick Updated Final Safety Analysis Report. Therefore, these details can be relocated to the TRM without a significant safety impact. Changes to the TRM are evaluated in accordance with 10 CFR 50.59, Changes, tests, and experiments, requirements.
In addition, precedent for the requested relocation has been established with Technical Specifications Task Force (TSTF) Traveler TSTF-266, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls (ML040620072) (TSTF-266), and Revision 2 of NUREG-1433 (ML011780639), which incorporated TSTF-266 into the Improved Standard Technical Specifications (ISTS). Moreover, relocation of the subject list of variables to the TRM is acceptable because its inclusion in the TSs does not fall within the criteria for mandatory inclusion in the TSs in 10 CFR 50.36(c)(2)(ii). The NRC staff finds that sufficient regulatory controls exist under the regulations to maintain the effect of the provisions in the TRM. Based on the above, the NRC staff finds that the proposed change is acceptable.
3.2 Revision to TS 3.3.7.4, ACTION a.
The licensee requested a revision to Limerick TS 3.3.7.4 ACTION a. to delete the reference to monitoring instrumentation channels as shown in the associated TS Table 3.3.7.4-1. The action would be simplified to state the entry condition for the action as:
With one or more of the required functions inoperable, restore the inoperable function(s) to OPERABLE status within 30 days or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."
The proposed deletion of the reference to monitoring instrumentation channels as shown in the associated TS Table 3.3.7.4-1 is acceptable for the reasons discussed in Section 3.1 above.
Adding a note of Separate ACTION entry is allowed for each function, to the current TS would permit separate entry into the required action, should more than one function be inoperable.
Without the proposed note, the new wording could be interpreted as not allowing separate entry for each function; thus, entry into the required actions for an inoperable channel of a second function would result in a plant shutdown per LCO 3.0.3. The proposed note is consistent with NUREG-1433. The NRC staff finds that these changes will ensure that the inoperable equipment is restored to an operable status and provide reasonable assurance that the licensee will comply with the regulations.
3.3 TS 3.3.7.4, ACTION a. Time Change The licensee proposed to revise TS 3.3.7.4, ACTION a. to change the required action time from 7 days to 30 days.
The proposed change in action time from 7 days to 30 days is based on operating experience and the low probability of an event occurring that would require the control room to be evacuated. In addition, precedent for extending the allowed outage time to 30 days has been established with TSTF-266 and Revision 2 of NUREG-1433, which incorporated TSTF-266 into the ISTS. Based on the above, the NRC staff finds that this proposed change is acceptable.
3.4 Deletion of TS 3.3.7.4, ACTION b.
The licensee proposed to delete TS 3.3.7.4, ACTION b., which states:
With the number of OPERABLE remote shutdown system controls less than required in Table 3.3.7.4-1, restore the inoperable control(s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
TS Table 3.3.7.4-1 is being deleted, as discussed in Section 3.1 above, and relocated to a licensee-controlled document; therefore, reference to it is no longer applicable. TS 3.3.7.4, ACTION a. is being revised to add the wording one or more of the required functions inoperable, which encompasses the required actions of TS 3.3.7.4, ACTION b. ACTION a. will continue to meet the requirements for an inoperable remote shutdown system control; therefore, TS 3.3.7.4, ACTION b. is no longer needed. Accordingly, the NRC staff finds that this proposed change is acceptable.
3.5 Deletion of TS Table 3.3.7.4-1 The licensee proposed to delete TS Table 3.3.7.4-1 and relocate the remote shutdown system equipment information to the TRM. The NRC staff reviewed this proposed change and finds it acceptable for the reasons discussed in Section 3.1 above.
3.6 Revisions to SR 4.3.7.4.1 and Addition of SR 4.3.7.4.3 The NRC staffs evaluation of the licensee-proposed changes to SR 4.3.7.4.1 and the addition of SR 4.3.7.4.3 is as follows:
a)
The licensee proposed to remove reference to TS Table 4.3.7.4-1, which is being deleted. The NRC staff finds this change acceptable for the reasons discussed in Section 3.1 above.
b)
The licensee proposed to relocate channel calibration to a new SR 4.3.7.4.3.
Currently, the SR to perform a channel calibration is located in SR 4.3.7.4.1. The licensee stated in the LAR that the proposed splitting out of the channel calibration into a new SR (SR 4.3.7.4.3) and rewording the SR would make it consistent with the ISTS. The NRC staff reviewed the change and determined that relocating the channel calibration to SR 4.3.7.4.3 continues to meet the requirements of 10 CFR 50.36(c)(3) for channel calibration of instrument channels because the proposed SR effectively maintains the existing TS requirement for a channel calibration. Therefore, the change is acceptable.
c)
The licensee proposed to add the statement normally energized to SR 4.3.7.4.1. This change would require the channel check only for normally energized required remote shutdown system instrumentation. The licensee stated in the LAR that performing a channel check of normally deenergized instrumentation is not practical or feasible during power operation. This change is consistent with ISTS SR 3.3.3.2.1. Based on the above, the NRC staff finds that the proposed change is acceptable.
d)
The proposed change to replace the with a in SR 4.3.7.4.1 is an administrative change to ensure that, with the revisions discussed above, the SR remains grammatically correct. Therefore, the proposed change is acceptable.
3.7 Revisions to SR 4.3.7.4.2 The licensee proposed to revise SR 4.3.7.4.2 by replacing Each of the above remote shutdown switch(es) and control circuits with Each required control circuit and transfer switch and by replacing function(s) with function. The licensee stated that these changes make the SR wording consistent with ISTS SR 3.3.3.2.2 and reflect the removal of TS Table 3.3.7.4-1. The NRC staff reviewed the proposed changes and determined that the revisions to SR 4.3.7.4.2 are functionally equivalent to the existing SR and continue to demonstrate that the required control circuit and control switch be operable. Therefore, the NRC staff finds these changes acceptable.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments on December 9, 2022. 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 or change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on June 14, 2022 (87 FR 36003).
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: T. Sweat, NRR Date: March 7, 2023
ML22348A176 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC NAME VSreenivas KZeleznock VCusumano DATE 12/9/2022 12/20/2022 11/17/2022 OFFICE OGC NLO NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME JWachutca HGonzalez VSreenivas DATE 01/06/2023 3/3/2023 3/7/2023