RS-23-050, Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube.

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Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube.
ML23143A136
Person / Time
Site: Calvert Cliffs, Braidwood, Ginna  Constellation icon.png
Issue date: 05/22/2023
From: Lueshen K
Constellation Energy Generation
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-23-050
Download: ML23143A136 (1)


Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-23-050 10 CFR 50.90 May 22, 2023 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

Subject:

Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections"

References:

1. Letter from K. Lueshen (Constellation Energy Generation, LLC) to U.S. Nuclear Regulatory Commission, "Application to Revise Technical Specifications to Adopt TSTF-577, 'Revised Frequencies for Steam Generator Tube Inspections'," dated August 10, 2022 (ADAMS Accession No. ML22222A068)
2. Email from J. Wiebe (U.S. Nuclear Regulatory Commission) to L. Simpson (Constellation Energy Generation, LLC), "Draft RAI for Adoption of TSTF-577,"

dated November 4, 2022

3. Letter from J. Wiebe (U.S. Nuclear Regulatory Commission) to D. Rhoades (Constellation Energy Generation, LLC), "Byron Station, Unit Nos. 1 and 2 -

Issuance of Amendments 231 and 231 Re: Adoption of TSTF-577, 'Revised Frequencies for Steam Generator Tube Inspections,' Revision 1 (EPID L-2022-LLA-0115)," dated December 28, 2022 (ADAMS Accession No. ML22305A699)

4. Letter from K. Lueshen (Constellation Energy Generation, LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, 'Revised Frequencies for Steam Generator Tube Inspections',"

dated December 7, 2022 (ADAMS Accession No. ML22342B230)

May 22, 2023 U.S. Nuclear Regulatory Commission Page 2 In Reference 1, Constellation Energy Generation, LLC (CEG) requested amendments to Renewed Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2 (Braidwood); Renewed Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2 (Byron); Renewed Facility Operating License Nos. DPR-53 and DPR-69 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Calvert Cliffs); and Renewed Facility Operating License No. DPR-18 for R.E. Ginna Nuclear Power Plant (Ginna).

The proposed changes would revise the "Steam Generator (SG) Program" and the "Steam Generator Tube Inspection Report" Technical Specifications (TS) based on Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revision 1, "Revised Frequencies for Steam Generator Tube Inspections" (TSTF-577) (ML21060B434), and the associated NRC safety evaluation (SE) (ML21098A188).

The CEG application (Reference 1) described plans to complete the required inspection of SG tubes in future outages, after the adoption of TSTF-577. In Reference 2, the U.S. Nuclear Regulatory Commission (NRC) requested additional information that was needed to complete review of the proposed changes specific to Braidwood, Calvert Cliffs, and Ginna. The request for additional information was not applicable to Byron. On December 28, 2022, Amendments 231 and 231 were issued for Byron, Units 1 and 2, regarding the adoption of TSTF-577 (Reference 3).

CEG provided additional information available as of December 2022 in Reference 4. As indicated in Reference 4, some of the outages to complete the 100% SG tube inspections had not yet transpired. With the completion of the 100% SG tube inspections described in the SG Program performed during the Braidwood Unit 2 spring refueling outage (A2R23) and the Ginna spring refueling outage (G1R44), this supplement provides an update to the site-specific inspection period information for each applicable unit provided in Reference 4. This supplement resolves the Variation regarding Ginna TS 5.5.8, paragraph d.2. Finally, this supplement eliminates the proposed license conditions from Reference 1 for Braidwood, Calvert Cliffs, and Ginna as they are no longer applicable.

CEG has reviewed the information supporting the finding of no significant hazards consideration, and the environmental consideration that were previously provided to the NRC in Reference 1.

The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments included in this letter.

CEG is notifying the State of Illinois, the State of Maryland, and the State of New York of this supplement to a previous application for a change to the operating license by sending a copy of this letter and its attachments to the designated Illinois, Maryland, and New York Officials in accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b).

If you should have any questions regarding this letter, please contact Ms. Lisa Simpson at (630) 657-2815.

May 22, 2023 U.S. Nuclear Regulatory Commission Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 22nd day of May 2023.

Respectfully, Lueshen, Digitally signed by Lueshen, Kevin Kevin Date: 2023.05.22 14:43:01

-05'00' Kevin Lueshen Sr. Manager - Licensing Constellation Energy Generation, LLC Attachments:

1) Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections" 2a) R.E. Ginna Nuclear Power Plant Proposed Technical Specifications Changes (Mark-up) 2b) R.E. Ginna Nuclear Power Plant Revised Technical Specifications Changes 3a) Braidwood Station, Units 1 and 2, Proposed Renewed Facility Operating License Changes (Revised Mark-up) 3b) Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Proposed Renewed Facility Operating License Changes (Revised Mark-up) 3c) R.E. Ginna Nuclear Power Plant Proposed Renewed Facility Operating License Changes (Revised Mark-up)

May 22, 2023 U.S. Nuclear Regulatory Commission Page 4 cc: NRC Project Manager - NRR - Braidwood / Byron NRC Project Manager - NRR - Calvert Cliffs NRC Project Manager - NRR - Ginna NRC Regional Administrator, Region I NRC Regional Administrator, Region III NRC Senior Resident Inspector, Braidwood Station NRC Senior Resident Inspector, Calvert Cliffs NRC Senior Resident Inspector, Ginna Illinois Emergency Management Agency - Division of Nuclear Safety A. L. Peterson, NYSERDA S. Seaman, State of Maryland

ATTACHMENT 1 Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections" In letter dated August 10, 2022 (Reference 1), Constellation Energy Generation, LLC (CEG) requested amendments to Renewed Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2 (Braidwood); Renewed Facility Operating License Nos.

NPF-37 and NPF-66 for Byron Station, Units 1 and 2 (Byron); Renewed Facility Operating License Nos. DPR-53 and DPR-69 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Calvert Cliffs); and Renewed Facility Operating License No. DPR-18 for R.E. Ginna Nuclear Power Plant (Ginna).

The proposed changes would revise the "Steam Generator (SG) Program" and the "Steam Generator Tube Inspection Report" Technical Specifications (TS) based on Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revision 1, "Revised Frequencies for Steam Generator Tube Inspections" (TSTF-577) (ML21060B434), and the associated NRC safety evaluation (SE) (ML21098A188).

The CEG application (Reference 1) described plans to complete the required inspection of SG tubes in future outages, after the adoption of TSTF-577. In Reference 2, the U.S. Nuclear Regulatory Commission (NRC) requested additional information that was needed to complete review of the proposed changes specific to Braidwood, Calvert Cliffs, and Ginna. The request for additional information was not applicable to Byron. On December 28, 2022, Amendments 231 were issued for Byron, Units 1 and 2, regarding the adoption of TSTF-577 (Reference 3).

CEG provided additional information available as of December 2022 in Reference 4. As discussed in the RAI Response (Reference 4), CEG will credit a 100% SG tube inspection performed during a single refueling outage for each unit prior to approval of the amendments.

With the completion of the 100% SG tube inspections described in the SG Program performed during the Braidwood Unit 2 spring refueling outage (A2R23) and the Ginna spring refueling outage (G1R44), all the CEG 100% SG tube inspections are complete.

An update to the site-specific inspection period information for each applicable unit is provided below. This supersedes the inspection period information provided in Reference 4; specifically, the information for Braidwood, Unit 2, and Ginna has been updated.

Braidwood, Unit 1:

The initial inspection period described in the SG Program, paragraph d.2, began October 18, 2022, for Braidwood, Unit 1. CEG will submit a SG Tube Inspection Report meeting the revised TS 5.6.9 requirements within 60 days after implementation of the license amendment.

Braidwood, Unit 2:

The initial inspection period described in the SG Program, paragraph d.3, began May 11, 2023, for Braidwood, Unit 2. CEG will submit a SG Tube Inspection Report meeting the revised TS 5.6.9 requirements within 60 days after implementation of the license amendment.

1 of 3

ATTACHMENT 1 Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections" Calvert Cliffs, Unit 1*:

The initial inspection period described in the SG Program, paragraph d.2, began March 9, 2020, for Calvert Cliffs, Unit 1. CEG will submit a SG Tube Inspection Report meeting the revised TS 5.6.9 requirements within 60 days after implementation of the license amendment.

Calvert Cliffs, Unit 2*:

The initial inspection period described in the SG Program, paragraph d.2, began March 14, 2019, for Calvert Cliffs, Unit 2. CEG will submit a SG Tube Inspection Report meeting the revised TS 5.6.9 requirements within 60 days after implementation of the license amendment.

  • Note: For Calvert Cliffs, Units 1 and 2, the dates provided in Reference 1 credited future outages in 2026 and 2025, respectively. In this letter, Calvert Cliffs, Units 1 and 2, credit a 100% SG tube inspection performed during a single refueling outage for each unit prior to approval of the amendments.

Ginna:

The initial inspection period described in the SG Program, paragraph d.2, began April 27, 2023, for Ginna. CEG will submit a SG Tube Inspection Report meeting the revised TS 5.6.7 requirements within 60 days after implementation of the license amendment.

Resolution of Variation Regarding Ginna TS 5.5.8, paragraph d.2 As discussed with the NRR Project Manager for Braidwood and Byron on January 11, 2023, Ginna TS 5.5.8, paragraph d.2, currently includes an exception that each SG is to be inspected during the spring 2023 refueling outage (G1R44). This variation was included in Reference 1 as the last bullet of Variation 6:

6) The Braidwood, Byron, Calvert Cliffs, and Ginna TS contain requirements that differ from the Standard Technical Specifications on which TSTF-577 was based but are encompassed in the TSTF-577 justification. Specifically:

Ginna TS 5.5.8.d.2 currently states: ", with the exception that each SG is to be inspected during the fourth refueling outage in G1R44 following inspections completed in refueling outage G1R40." CEG plans to inspect 100% of the SG tubes during the spring 2023 refueling outage (G1R44) in support of the amendment implementation activities.

This supplement resolves the Variation regarding Ginna TS 5.5.8, paragraph d.2. With the initial 100% SG tube inspection period described in the Ginna SG Program (TS 5.5.8) beginning on April 27, 2023, for Ginna (i.e., date Ginna entered MODE 4 at the end of the spring 2023 G1R44 refueling outage), the 100% SG tube inspection required by TS 5.5.8 and TSTF-577 was performed.

2 of 3

ATTACHMENT 1 Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections" The Variation regarding Ginna TS 5.5.8.d.2 is no longer needed. Attachment 2a provides an update to the existing Ginna TS pages, marked up to show the proposed changes, including the elimination of the above exception related to G1R44. The changes to TS 5.5.8 and TS 5.6.7 also include minor formatting changes to resolve spacing errors with the Ginna TS (i.e., no substantive changes). Attachment 2b provides revised (clean) TS pages for Ginna.

Elimination of Proposed License Conditions The proposed license conditions provided in Reference 1 for Braidwood, Units 1 and 2, Calvert Cliffs, Units 1 and 2, and Ginna are no longer applicable with the performance of the 100% SG tube inspections required by TS. Attachments 3a through 3c of this supplement provide updates to the proposed license conditions from Reference 1 for Braidwood, Calvert Cliffs, and Ginna, eliminating the proposed license conditions for clarity.

REFERENCES

1. Letter from K. Lueshen (Constellation Energy Generation, LLC) to U.S. Nuclear Regulatory Commission, "Application to Revise Technical Specifications to Adopt TSTF-577, 'Revised Frequencies for Steam Generator Tube Inspections'," dated August 10, 2022 (ADAMS Accession No. ML22222A068)
2. Email from J. Wiebe (U.S. Nuclear Regulatory Commission) to L. Simpson (Constellation Energy Generation, LLC), "Draft RAI for Adoption of TSTF-577," dated November 4, 2022
3. Letter from J. Wiebe (U.S. Nuclear Regulatory Commission) to D. Rhoades (Constellation Energy Generation, LLC), "Byron Station, Unit Nos. 1 and 2 - Issuance of Amendments 231 and 231 Re: Adoption of TSTF-577, 'Revised Frequencies for Steam Generator Tube Inspections,' Revision 1 (EPID L-2022-LLA-0115)," dated December 28, 2022 (ADAMS Accession No. ML22305A699)
4. Letter from K. Lueshen (Constellation Energy Generation, LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, 'Revised Frequencies for Steam Generator Tube Inspections'," dated December 7, 2022 (ADAMS Accession No. ML22342B230) 3 of 3

Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections" Attachment 2a R.E. Ginna Nuclear Power Plant Proposed Technical Specifications Changes (Mark-up)

NRC Docket No. 50-244 TS Page 3.4.17-1 TS Page 3.4.17-2 TS Page 5.5-5 TS Page 5.5-6 (updated)

TS Page 5.6-5 Ginna TS Inserts

SG Tube Integrity 3.4.17 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.17 Steam Generator (SG) Tube Integrity LCO 3.4.17 SG tube integrity shall be maintained.

AND plugging All SG tubes satisfying the tube repair criteria shall be plugged in accordance with the Steam Generator Program.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

- NOTE -

Separate Condition entry is allowed for each SG tube.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more SG tubes A.1 Verify tube integrity of the 7 days satisfying the tube repair affected tube(s) is criteria and not plugged in maintained until the next accordance with the refueling outage or SG tube Steam Generator inspection.

Program.

plugging AND A.2 Plug the affected tube(s) in Prior to entering accordance with the Steam MODE 4 following Generator Program. the next refueling outage or SG tube inspection B. Required Action and B.1 Be in MODE 3 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR SG tube integrity not maintained.

R.E. Ginna Nuclear Power Plant 3.4.17-1 Amendment 100

SG Tube Integrity 3.4.17 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify SG tube integrity in accordance with the Steam In accordance with Generator Program. the Steam Generator Program SR 3.4.17.2 Verify that each inspected SG tube that satisfies the Prior to entering tube repair criteria is plugged in accordance with the MODE 4 following a Steam Generator Program. SG tube inspection plugging R.E. Ginna Nuclear Power Plant 3.4.17-2 Amendment 100

Programs and Manuals 5.5 SG 5.5.8 n Steam Generator (SG) Program SG A Steam Generator Program shall be established and implemented to ensure that SG tube integrity is maintained. In addition, the Steam Generator Program shall include the following provisions:

a. Provisions for condition monitoring assessments. Condition monitoring assessment means an evaluation of the "as found" condition of the tubing with respect to the performance criteria for structural integrity and accident induced leakage. The "as found" condition refers to the condition of the tubing during an SG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging of tubes. Condition monitoring assessments shall be conducted during each outage during which the SG tubes are inspected or plugged, to confirm that the performance criteria are being met. SG
b. Performance criteria for SG tube integrity. Steam generator tube integrity shall be maintained by meeting the performance criteria for tube structural integrity, accident induced leakage, and operational LEAKAGE. SG
1. Structural integrity performance criterion: All in-service steam generator tubes shall retain structural integrity over the full range of normal operating conditions (including startup, ),

operation in the power range, hot standby, and cool down and ,

all anticipated transients included in the design specification) and design basis accidents. This includes retaining a safety factor of 3.0 against burst under normal steady-state full power operation primary to secondary pressure differential steady state and a safety factor of 1.4 against burst applied to the design primary-to-secondary basis accident primary-to-secondary pressure differentials.

Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse.

In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.

2. Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for each SG. Leakage is not to exceed 1 gpm per SG.

R.E. Ginna Nuclear Power Plant 5.5-5 Amendment 110

Programs and Manuals 5.5 plugging

3. The operational LEAKAGE performance criterion is specified in LCO 3.4.13, "RCS Operational LEAKAGE."
c. Provisions for SG tube repair criteria. Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding 40%

of the nominal tube wall thickness shall be plugged.

d. Provisions for SG tube inspections. Periodic SG tube inspections shall be performed. The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial, and circumferential cracks) that may be present along the length of the tube, from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet, and that may satisfy the applicable tube repair criteria. The tube-to-tubesheet weld is not plugging part of the tube. In addition to meeting the requirements of d.1, d.2, and d.3 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. An assessment of degradation shall be performed to determine the type and assessment location of flaws to which the tubes may be susceptible and, based on this assessment, to determine which inspection methods need to be employed and at what locations.
1. Inspect 100% of the tubes in each SG during the first refueling outage following SG replacement.

installation

2. Inspect 100% of the tubes at sequential periods of 144, 108, 72, and, thereafter, 60 effective full power months. The first sequential period shall be considered to begin after the first inservice inspection of the SGs. In addition, inspect 50% of INSERT: the tubes by the refueling outage nearest the midpoint of the Ginna TS 5.5.8.d.2 period and the remaining 50% by the refueling outage nearest the end of the period. No SG shall operate for more than 72 effective full power months or three refueling outages (whichever is less) without being inspected, with the exception that each SG is to be inspected during the fourth refueling outage in G1R44 following inspections completed affected and in refueling outage G1R40.

be at the next potentially affected

3. If crack indications are found in any SG tube, then the next inspection for each SG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever is less). If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.
e. Provisions for monitoring operational primary to secondary LEAKAGE R.E. Ginna Nuclear Power Plant 5.5-6 Amendment 110, 145

Reporting Requirements 5.6

2. As an alternative to the use of WCAP-14040-A Section 3.2 methodology, the existing Ginna specific LTOP Setpoint Methodology submitted to the NRC in the letter to Guy S.

Vissing (NRC) from Robert C. Mecredy (RG&E), "Application for Amendment to Facility Operating License, Revision to Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR) Administrative Controls Requirements,"

Attachment VI, Section 3.2, dated September 29, 1997 and approved in letter to Robert C. Mecredy (RG&E) from S.

Singh Bajwa (NRC), "R.E. Ginna - Acceptance for Referencing of Pressure Temperature Limits Report,"

Revision 2 (TAC No. M96529), dated November 28, 1997, may be utilized.

d. The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for revisions or supplement thereto.

5.6.7 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5.5.8, Steam Generator (SG) Program. The report shall include:

a. The scope of inspections performed on each SG,
b. Active degradation mechanisms found,
c. Nondestructive examination techniques utilized for each degradation mechanism,
d. Location, orientation (if linear), and measured sizes (if available) of service induced indications,
e. Number of tubes plugged during the inspection outage for each active degradation mechanism, INSERT:

Ginna f. Total number and percentage of tubes plugged to date, and TS 5.6.7

g. The results of condition monitoring, including the results of tube pulls and in-situ testing.

R.E. Ginna Nuclear Power Plant 5.6-5 Amendment 106

Ginna TS Inserts INSERT: Ginna TS 5.5.8.d.2 After the first refueling outage following SG installation, inspect 100% of the tubes in each SG at least every 96 effective full power months, which defines the inspection period INSERT: Ginna TS 5.6.7

b. The nondestructive examination techniques utilized for tubes with increased degradation susceptibility;
c. For each degradation mechanism found:
1. The nondestructive examination techniques utilized;
2. The location, orientation (if linear), measured size (if available), and voltage response for each indication. For tube wear at support structures less than 20 percent through-wall, only the total number of indications needs to be reported;
3. A description of the condition monitoring assessment and results, including the margin to the tube integrity performance criteria and comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment; and
4. The number of tubes plugged during the inspection outage.
d. An analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria, including the analysis methodology, inputs, and results;
e. The number and percentage of tubes plugged to date, and the effective plugging percentage in each SG; and
f. The results of any SG secondary side inspections.

Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections" Attachment 2b R.E. Ginna Nuclear Power Plant Revised Technical Specifications Changes NRC Docket No. 50-244 TS Page 3.4.17-1 TS Page 3.4.17-2 TS Page 5.5-5 TS Page 5.5-6 (updated)

TS Page 5.6-5 TS Page 5.6-6

SG Tube Integrity 3.4.17 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.17 Steam Generator (SG) Tube Integrity LCO 3.4.17 SG tube integrity shall be maintained.

AND All SG tubes satisfying the tube plugging criteria shall be plugged in accordance with the Steam Generator Program.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

- NOTE -

Separate Condition entry is allowed for each SG tube.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more SG tubes A.1 Verify tube integrity of the 7 days satisfying the tube affected tube(s) is plugging criteria and not maintained until the next plugged in accordance refueling outage or SG tube with the Steam Generator inspection.

Program.

AND A.2 Plug the affected tube(s) in Prior to entering accordance with the Steam MODE 4 following Generator Program. the next refueling outage or SG tube inspection B. Required Action and B.1 Be in MODE 3 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR SG tube integrity not maintained.

R.E. Ginna Nuclear Power Plant 3.4.17-1 Amendment

SG Tube Integrity 3.4.17 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify SG tube integrity in accordance with the Steam In accordance with Generator Program. the Steam Generator Program SR 3.4.17.2 Verify that each inspected SG tube that satisfies the Prior to entering tube plugging criteria is plugged in accordance with MODE 4 following a the Steam Generator Program. SG tube inspection R.E. Ginna Nuclear Power Plant 3.4.17-2 Amendment

Programs and Manuals 5.5 5.5.8 Steam Generator (SG) Program An SG Program shall be established and implemented to ensure that SG tube integrity is maintained. In addition, the SG Program shall include the following:

a. Provisions for condition monitoring assessments. Condition monitoring assessment means an evaluation of the "as found" condition of the tubing with respect to the performance criteria for structural integrity and accident induced leakage. The "as found" condition refers to the condition of the tubing during an SG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging of tubes. Condition monitoring assessments shall be conducted during each outage during which the SG tubes are inspected or plugged, to confirm that the performance criteria are being met.
b. Performance criteria for SG tube integrity. SG tube integrity shall be maintained by meeting the performance criteria for tube structural integrity, accident induced leakage, and operational LEAKAGE.
1. Structural integrity performance criterion: All in-service SG tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, and cool down), all anticipated transients included in the design specification, and design basis accidents. This includes retaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials.

Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse.

In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.

2. Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for each SG. Leakage is not to exceed 1 gpm per SG.

R.E. Ginna Nuclear Power Plant 5.5-5 Amendment

Programs and Manuals 5.5

3. The operational LEAKAGE performance criterion is specified in LCO 3.4.13, "RCS Operational LEAKAGE."
c. Provisions for SG tube plugging criteria. Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged.
d. Provisions for SG tube inspections. Periodic SG tube inspections shall be performed. The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial, and circumferential cracks) that may be present along the length of the tube, from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet, and that may satisfy the applicable tube plugging criteria. The tube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements of d.1, d.2, and d.3 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. A degradation assessment shall be performed to determine the type and location of flaws to which the tubes may be susceptible and, based on this assessment, to determine which inspection methods need to be employed and at what locations.
1. Inspect 100% of the tubes in each SG during the first refueling outage following SG installation.
2. After the first refueling outage following SG installation, inspect 100% of the tubes in each SG at least every 96 effective full power months, which defines the inspection period.
3. If crack indications are found in any SG tube, then the next inspection for each affected and potentially affected SG for the degradation mechanism that caused the crack indication shall be at the next refueling outage. If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.
e. Provisions for monitoring operational primary to secondary LEAKAGE R.E. Ginna Nuclear Power Plant 5.5-6 Amendment

Reporting Requirements 5.6

2. As an alternative to the use of WCAP-14040-A Section 3.2 methodology, the existing Ginna specific LTOP Setpoint Methodology submitted to the NRC in the letter to Guy S.

Vissing (NRC) from Robert C. Mecredy (RG&E), "Application for Amendment to Facility Operating License, Revision to Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR) Administrative Controls Requirements,"

Attachment VI, Section 3.2, dated September 29, 1997 and approved in letter to Robert C. Mecredy (RG&E) from S.

Singh Bajwa (NRC), "R.E. Ginna - Acceptance for Referencing of Pressure Temperature Limits Report,"

Revision 2 (TAC No. M96529), dated November 28, 1997, may be utilized.

d. The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for revisions or supplement thereto.

5.6.7 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5.5.8, Steam Generator (SG) Program. The report shall include:

a. The scope of inspections performed on each SG;
b. The nondestructive examination techniques utilized for tubes with increased degradation susceptibility;
c. For each degradation mechanism found:
1. The nondestructive examination techniques utilized;
2. The location, orientation (if linear), measured size (if available),

and voltage response for each indication. For tube wear at support structures less than 20 percent through-wall, only the total number of indications needs to be reported;

3. A description of the condition monitoring assessment and results, including the margin to the tube integrity performance criteria and comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment; and
4. The number of tubes plugged during the inspection outage.

R.E. Ginna Nuclear Power Plant 5.6-5 Amendment

Reporting Requirements 5.6

d. An analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria, including the analysis methodology, inputs, and results;
e. The number and percentage of tubes plugged to date, and the effective plugging percentage in each SG; and
f. The results of any SG secondary side inspections.

R.E. Ginna Nuclear Power Plant 5.6-6 Amendment

Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections" Attachment 3a Braidwood Station, Units 1 and 2, Proposed Renewed Facility Operating License Changes (Revised Mark-up)

NRC Docket Nos. STN 50-456 and STN 50-457 Renewed Facility Operating License Nos. NPF-72 and NPF-77 Unit 1 RFOL Page 6 Unit 2 RFOL Page 6 (No changes)

Unit 2 RFOL Page 7 RFOL INSERTS



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RFOL INSERTS UNIT 1 RFOL License Condition 2.C.(15)

(15) Adoption of TSTF-577, Revision 1, "Revised Frequencies for Steam Generator Tube Inspections" The extended inspection interval of TS 5.5.9 will not be permitted following implementation of the TSTF-577 amendment until after performance of a 100% inspection of all tubes in a single outage.

UNIT 2 RFOL License Condition 2.C.(14)

(14) Adoption of TSTF-577, Revision 1, "Revised Frequencies for Steam Generator Tube Inspections" The extended inspection interval of TS 5.5.9 will not be permitted following implementation of the TSTF-577 amendment until after performance of a 100% inspection of all tubes in a single outage.

Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections" Attachment 3b Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Proposed Renewed Facility Operating License Changes (Revised Mark-up)

NRC Docket Nos. 50-317 and 50-318 Renewed Facility Operating License Nos. DPR-53 and DPR-69 Unit 1 RFOL Page 5 Unit 2 RFOL Page 6 RFOL INSERTS

(c) Actions to minimize release to include consideration of:

1. Water spray scrubbing
2. Dose to onsite responders (6) Risk-Informed Categorization and Treatment of Structures, Systems, and Components Constellation Energy Generation, LLC is approved to implement 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 Structures, Systems, and Components (SSCs) using: Probabilistic Risk Assessment (PRA) models to evaluate risk associated with internal events, including internal flooding, and internal fire; the shutdown safety assessment process to assess shutdown risk; the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method to assess passive component risk for Class 2 and Class 3 and non-Class SSCs and their associated supports: the results of the non-PRA evaluations that are based on the IPEEE Screening Assessment for External Hazards updated using the external hazard screening significance process identified in ASME/ANS PRA Standard RA-Sa-2009 for other external hazards except seismic: and the alternative seismic approach as described in Exelons original submittal letter dated November 28, 2018, and all its subsequent associated supplements as specified in License Amendment No. 332 dated February 28, 2020.

Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach).

(7) Constellation Energy Generation, LLC shall provide to the Director of the Office of Nuclear Reactor Regulation or the Director of the Office of Nuclear Material Safety and Safeguards, as applicable, a copy of any application, at the time it is filed, to transfer (excluding grants of security interests or liens) from INSERT: Constellation Energy Generation, LLC to its direct or indirect parent, or to any License Condition other affiliated company, facilities for the production, transmission, or 2.C.(8) distribution of electric energy having a depreciated book value exceeding ten percent (10%) of Constellation Energy Generation, LLCs consolidated net utility plant, as recorded on Constellation Energy Generation, LLCs books of account.

D. Constellation Energy Generation, LLC shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency. plans, including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: Calvert Cliffs Nuclear Power Plant Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 1 submitted May 19, 2006.

Constellation Energy Generation, LLC shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensees Amendment No. 343

Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach).

(9) Constellation Energy Generation, LLC shall provide to the Director of the Office of Nuclear Reactor Regulation or the Director of the Office of Nuclear Material Safety and Safeguards, as applicable, a copy of any application, at the time it is filed, to transfer (excluding grants of security interests or liens) from INSERT: Constellation Energy Generation, LLC to its direct or indirect parent, or to any License Condition other affiliated company, facilities for the production, transmission, or 2.C.(10) distribution of electric energy having a depreciated book value exceeding ten percent (10%) of Constellation Energy Generation, LLCs consolidated net utility plant, as recorded on Constellation Energy Generation, LLCs books of account.

D. Constellation Energy Generation, LLC shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans, including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: Calvert Cliffs Nuclear Power Plant Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 1 submitted dated May 19, 2006.

Constellation Energy Generation, LLC shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensees CSP was approved by License Amendment No. 275 and modified by License Amendment No. 290.

E. Constellation Energy Generation, LLC shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated September 24, 2013; as supplemented by letters dated February 9, 2015, March 11, 2015, April 13, 2015, July 6, 2015, August 13, 2015, February 24, 2016, and April 22, 2016, and as approved in the NRC safety evaluation dated August 30, 2016. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), and the criteria listed below are satisfied.

Amendment 321

RFOL INSERTS UNIT 1 RFOL License Condition 2.C.(8)

(8) Adoption of TSTF-577, Revision 1, "Revised Frequencies for Steam Generator Tube Inspections" The extended inspection interval of TS 5.5.9 will not be permitted following implementation of the TSTF-577 amendment until after performance of a 100% inspection of all tubes in a single outage.

UNIT 2 RFOL License Condition 2.C.(10)

(10) Adoption of TSTF-577, Revision 1, "Revised Frequencies for Steam Generator Tube Inspections" The extended inspection interval of TS 5.5.9 will not be permitted following implementation of the TSTF-577 amendment until after performance of a 100% inspection of all tubes in a single outage.

Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections" Attachment 3c R.E. Ginna Nuclear Power Plant Proposed Renewed Facility Operating License Changes (Revised Mark-up)

NRC Docket No. 50-244 Renewed License No. DPR-244 RFOL Page 9 RFOL INSERT

(17) Adoption of Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times -RITSTF Initiative 4b Constellation Energy Generation, LLC is approved to implement TSTF-505, Revision 2, modifying the Technical Specification requirements related to Completion Times (CT) for Required Actions to provide the option to calculate a longer, risk-informed CT (RICT). The methodology for using the new Risk-Informed Completion Time Program is described in NEI 06-09-A, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines, Revision 0, which was approved by the NRC on May 17, 2007.

Constellation Energy Generation, LLC will complete the implementation items listed in Attachment 6 of Exelon Letter to the NRC dated May 20, 2021, prior to implementation of the RICT Program. All issues identified in the attachment will be addressed and any associated changes will be made, focused-scope peer reviews will be performed on changes that are PRA upgrades as defined in the PRA standard (ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2), and any findings will be resolved and reflected in the PRA of record prior to the implementation of the RICT Program.

(18) Deleted (19) Constellation Energy Generation, LLC shall provide to the Director of the Office of Nuclear Reactor Regulation or the Director of the Office of Nuclear Material Safety and Safeguards, as applicable, a copy of any application, at the time it is filed, to transfer (excluding grants of security interests or liens) from Constellation Energy Generation, LLC to its direct INSERT: or indirect parent, or to any other affiliate company, facilities for the License Condition production, transmission, or distribution of electric energy having a depreciated book value exceeding ten percent (10%) of Constellation 2.C.(20)

Energy Generation, LLCs consolidated net utility plant, as recorded on Constellation Energy Generation, LLCs books of account.

D. The facility requires an exemption from certain requirements of 10 CFR 50.46(a)(1). This includes an exemption from 50.46(a)(1), that emergency core cooling system (ECCS) performance be calculated in accordance with an acceptable calculational model which conforms to the provisions in Appendix K (SER dated April 18, 1978). The exemption will expire upon receipt and approval of revised ECCS calculations. The aforementioned exemption is authorized by law and will not endanger life property or the common defense and security and is otherwise in the public interest. Therefore, the exemption is hereby granted pursuant to 10 CFR 50.12.

R. E. Ginna Nuclear Power Plant Amendment No. 150

RFOL INSERT RFOL License Condition 2.C.(20)

(20) Adoption of TSTF-577, Revision 1, "Revised Frequencies for Steam Generator Tube Inspections" The extended inspection interval of TS 5.5.8 will not be permitted following implementation of the TSTF-577 amendment until after performance of a 100% inspection of all tubes in a single outage.