ML23005A008

Technical Specifications to Correct Non-conservative Technical Specification Table 3.3.2-1 for Main Steam Line Isolation Trip Function 1.G (EPID L 2020 Lla 0034) Amds. 259 and 221

ML23005A008
Person / Time
Site:	Limerick
Issue date:	02/23/2023
From:	V Sreenivas Plant Licensing Branch 1
To:	Rhoades D Constellation Energy Generation
Sreenivas V, NRR/DORL/LPLI, 415-2597
References
EPID L-2020-LLA-0034
Download: ML23005A008 (17)

Text

February 23, 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 AMENDMENTS NOS. 259 AND 221 REGARDING TECHNICAL SPECIFICATIONS TO CORRECT NONCONSERVATIVE TECHNICAL SPECIFICATION TABLE 3.3.2-1 FOR MAIN STEAM LINE ISOLATION TRIP FUNCTION 1.G (EPID L-2020-LLA-0034)

Dear Mr. Rhoades:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 259 to Renewed Facility Operating License No. NPF-39, and Amendment No. 221 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 (ADAMS) Accession No. ML22055A600).

The amendments revise the Technical Specifications (TSs) table 3.3.2-1, Isolation Actuation Instrumentation, Trip Function 1.g for Main Steam Line Isolation to correct an administrative error.

D. Rhoades A copy of the 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.259 to NPF-39

2. Amendment No. 221 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. 259 Renewed License No. NPF-39

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

A. The application for amendment by Constellation Generation Company, LLC (Constellation Generation Company), 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.

Enclosure 1

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. 259, are hereby incorporated into this renewed license. Constellation Energy 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 the date of its issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Richard Richard V. V. Guzman Date: 2023.02.23 16:36:01 Guzman -05'00' 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: February 23, 2023

ATTACHMENT TO LICENSE AMENDMENT NO. 259 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 4 4 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contain a marginal line indicating the areas of change.

Remove Page Insert Page 3/4 3-11 3/4 3-11

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 259, 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. 259

TABLE 3.3.2-1 ISOLATION ACTUATION INSTRUMENTATION MINIMUM APPLICABLE ISOLATION OPERABLE CHANNELS OPERATIONAL TRIP FUNCTION SIGNAL (a) PER TRIP SYSTEM (b) CONDITION ACTION

1. MAIN STEAM LINE ISOLATION

a. Reactor Vessel Water Level

1) Low, Low-Level 2 B 2 1, 2, 3 21

2) Low, Low, Low-Level 1 C 2 1, 2, 3 21

b. DELETED DELETED DELETED DELETED DELETED

c. Main Steam Line Pressure - Low P 2 1 22

d. Main Steam Line Flow - High E 2/line 1, 2, 3 20

e. Condenser Vacuum - Low Q 2 1, 2**, 3** 21

f. Outboard MSIV Room Temperature - High F(f) 2 1, 2, 3 21

g. Turbine Enclosure - Main Steam Line Tunnel Temperature - High F(f) 16 1, 2, 3 21

h. Manual Initiation NA 2 1, 2, 3 24

2. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a. Reactor Vessel Water Level Low - Level 3 A 2 1, 2, 3 23

b. Reactor Vessel (RHR Cut-In Permissive) Pressure - High V 2 1, 2, 3 23

c. Manual Initiation NA 1 1, 2, 3 24 LIMERICK - UNIT 1 3/4 3-11 Amendment No. 28, 89, 259, zxxx

CONSTELLATION ENERGY GENERATION, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 221 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 (Constellation Energy Generation), 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.

Enclosure 2

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. 221, are hereby incorporated into this renewed license. Constellation Energy Generation 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 Digitally signed by Richard Richard V. V. Guzman Date: 2023.02.23 16:37:54 Guzman -05'00' 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: February 23, 2023

ATTACHMENT TO LICENSE AMENDMENT NO. 221 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 contain a marginal line indicating the areas of change.

Remove Page Insert Page 3/4 3-11 3/4 3-11

(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. 221, 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. 221

TABLE 3.3.2-1 ISOLATION ACTUATION INSTRUMENTATION MINIMUM APPLICABLE ISOLATION OPERABLE CHANNELS OPERATIONAL TRIP FUNCTION SIGNAL (a) PER TRIP SYSTEM (b) CONDITION ACTION

1. MAIN STEAM LINE ISOLATION

a. Reactor Vessel Water Level

1) Low, Low-Level 2 B 2 1, 2, 3 21

2) Low, Low, Low-Level 1 C 2 1, 2, 3 21

b. DELETED DELETED DELETED DELETED DELETED

c. Main Steam Line Pressure - Low P 2 1 22

d. Main Steam Line Flow - High E 2/line 1, 2, 3 20

e. Condenser Vacuum - Low Q 2 1, 2**, 3** 21

f. Outboard MSIV Room Temperature - High F(f) 2 1, 2, 3 21

g. Turbine Enclosure - Main Steam Line Tunnel Temperature - High F(f) 16 1, 2, 3 21

h. Manual Initiation NA 2 1, 2, 3 24

2. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a. Reactor Vessel Water Level Low - Level 3 A 2 1, 2, 3 23

b. Reactor Vessel (RHR Cut-In Permissive) Pressure - High V 2 1, 2, 3 23

c. Manual Initiation NA 1 1, 2, 3 24 LIMERICK - UNIT 2 3/4 3-11 Amendment No. 52, 221

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 259 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-39 AND AMENDMENT NO. 221 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 to the U.S. Nuclear Regulatory Commission (NRC, the Commission) dated February 24, 2022 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML22055A600), Constellation Energy Generation, LLC (Constellation, the licensee) submitted a license amendment request (LAR) to revise Technical Specification (TS) table 3.3.2-1, Isolation Actuation Instrumentation, Trip Function 1.g for Main Steam Line Isolation table to correct an error introduced by a previous license amendment that modified TS 3.3.2, Isolation Actuation Instrumentation, among several changes to the Limerick Generating Station, Units 1 and 2 technical specifications. The previous license amendment also revised TS requirements related to reactor coolant leakage, minimum shift crew composition, temperature sensors used to detect leakage, a snubber surveillance, and hydrogen recombiner phase resistance; however, those changes are not relevant to the proposed change in the current LAR.

2.0 REGULATORY EVALUATION

2.1 Description of the Proposed TS Changes In the LAR, the licensee proposed a change to Limerick TS table 3.3.2-1, Isolation Actuation Instrumentation. For Trip Function 1.g, Turbine Enclosure - Main Steam Line Tunnel Temperature - High, the minimum operable channels per trip system would be changed from 14 to 16 to correct an error introduced by a previous license amendment that caused the TS requirement to be non-conservative. The licensee stated in the LAR that the proposed change would correct TS table 3.3.2-1 so that it is consistent with the current design basis. The licensee did not propose any physical changes to the plant.

As indicated in the LAR, an error was inadvertently introduced by a previous LAR for Limerick, Unit 1, dated April 10, 1989 (ML20244B278). This change was approved in Limerick, Unit 1, License Amendment No. 28 (ML011520366). Because the TSs for Limerick, Unit 2, were developed based on the TSs for Limerick, Unit 1, the error was propagated for Unit 2 as well.

Enclosure 3

The 1989 LAR described the change to TS table 3.3.2-1 Trip Function 1.g for Limerick, Unit 1, as follows:

Technical Specification Tables 3.3.2-1, 3.3.2-2, 3.3.2-3, and 4.3.2.1-1 are proposed to be revised indicating two specific locations monitored by the Main Steam Isolation Valve - Leakage Detection System (MSIV-LDS). The change revises Item 1.f to denote the Outboard MSIV Room Temperature - High. The second location is specified by Item 1.g which will continue to denote the Turbine Enclosure - Main Steam Line Tunnel - High. Recognizing that setpoints for the temperature sensors depend upon the area in which the sensors are located, Item 1.f will reflect the four (4) GE temperature sensors located in the Outboard MSIV Room with a specified setpoint of 192 degrees F [degF]. The minimum operable channels per Trip System will be revised to two (2). This corresponds to the total number of sensors located in this area. The remaining twelve (12) GE temperature sensors located in the Turbine Enclosure will be reflected in Item 1.g with a specified setpoint of 165 degF. The minimum number of operable channels will be revised to fourteen (14).

The licensee justified these changes to items 1.f and 1.g in the 1989 LAR as correcting inaccurate information in the TS to be consistent with Limerick, Unit 1, current licensing basis.

However, the 1989 LAR introduced another error by incorrectly proposing for item 1.g a requirement of 14 as the minimum number of operable channels.

2.2 Regulatory Requirements Used in the Evaluation of the Changes Title 10 of the Code of Federal Regulations (10 CFR) 50.36, Technical specifications, provides the regulatory requirements for the content of the TSs. Specifically, 10 CFR 50.36(c) requires that TSs include items in five specific categories related to station operation. These categories are (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls.

10 CFR 50.36(c)(1)(ii)(A) requires, in part, that where a limiting safety system setting is specified for a variable on which a safety limit has been placed, the setting must be so chosen that automatic protective action will correct the abnormal situation before a safety limit is exceeded.

10 CFR 50.36(c)(2)(i) states, in part, that TSs will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility.

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the LAR and the Limerick, Units 1 and 2, updated final safety analysis report (UFSAR). UFSAR section 7.6.1.3.3.2.2 describes the main steam line temperature in the outboard MSIV room and turbine enclosure main steam tunnel monitoring subsystem -

instrumentation and controls. Dual element thermocouples are used to detect high temperatures near the main steam lines and are positioned above the main steam lines between the primary containment wall and the turbine. The purpose of this temperature detection system is to identify steam leaks equivalent to five gallons per minute. There are four outboard MSIV room main steam line high ambient temperature channels and 32 channels on the main steam line in the turbine enclosure. The output trip signal of each logic channel initiates a trip logic to trip one of

two redundant divisions of the monitoring system for the main steam line drains; there are 16 temperature channels on the turbine side of each division.

The NRC staff notes that the LAR does not propose changes to requirements for trip function 1.g in the other associated tables mentioned in the 1989 LAR. Expressly, the proposed change does not involve or impact a change to any safety limits, limiting safety system settings, LCOs, setpoints or design parameters, and response time in TS table 3.3.2-2, Isolation Actuation Instrumentation Setpoints, and TS table 3.3.2-3, Isolation System Instrumentation Response Time.

3.1 Technical Conclusion Based on the technical evaluation provided above, the NRC staff finds the licensee has demonstrated that the Limerick TS change would align with the current licensing basis as stated in the associated UFSAR, without modifying the plant design or safety analysis. The change would correct a non-conservative requirement in TS table 3.3.2-1. Therefore, the NRC staff finds acceptable the correction to the number of minimum operable channels from 14 to 16 per trip system for Trip Function 1.g, Turbine Enclosure - Main Steam Line Tunnel Temperature -

High. Further, the NRC staff finds the proposed change would restore compliance with 10 CFR 50.36 paragraphs (c)(1)(ii)(A) and (c)(2)(i) by maintaining the limiting safety system settings and providing in the TS the lowest functional capability or performance levels of equipment for safe operation of the facility.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments on January 4, 2023. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or changes 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 36007).

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 Contributors: K. West, NRR Date: February 23, 2023

D. Rhoades

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS NOS. 259 AND 221 REGARDING TECHNICAL SPECIFICATIONS TO CORRECT NONCONSERVATIVE TECHNICAL SPECIFICATION TABLE 3.3.2-1 FOR MAIN STEAM LINE ISOLATION TRIP FUNCTION 1.G (EPID L-2020-LLA-0034) DATED FEBRUARY 23, 2023 DISTRIBUTION:

PUBLIC PM File Copy RidsACRS_MailCTR Resource RidsNrrDorlLpl1 Resource RidsNrrDssStsb Resource RidsNrrLAKZeleznock Resource RidsNrrLAKEntz Resource RidsNrrPMLimerick Resource RidsRgn1MailCenter Resource ADAMS Accession No.: ML23005A008 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC OGC NLO NAME VSreenivas KZeleznock (KEntz for) VCusumano ELicon DATE 1/10/2023 1/10/2023 10/7/2022 2/1/2023 OFFICE NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME HGonzález (RGuzman for) VSreenivas DATE 2/23/2023 2/23/2023