ML23271A004
| ML23271A004 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/24/2023 |
| From: | Hipolito Gonzalez Plant Licensing Branch 1 |
| To: | |
| Sreenivas V, NRR/DORL/LPLI, 415-2597 | |
| References | |
| EPID L-2023-LLA-0025, NRC-2023-0182 | |
| Download: ML23271A004 (1) | |
Text
[7590-01-P]
NUCLEAR REGULATORY COMMISSION
[Docket Nos. 50-352 and 50-353; NRC-2023-0182]
Constellation Energy Generation, LLC;
Limerick Generating Station, Units 1 and 2
AGENCY: Nuclear Regulatory Commission.
ACTION: License amendment application; opportunity to comment, request a hearing,
and petition for leave to intervene.
SUMMARY
- The U.S. Nuclear Regulatory Commission (NRC, the Commission) is
considering issuance of an amendment to Renewed Facility Operating License Nos.
NPF-39 and NPF-85, issued to Constellation Energy Generation, LLC, for operation of
the Limerick Generating Station, Units 1 and 2 (Limerick). The amendment would (1)
make changes to technical specifications (TS) affecting postulated accidents during cold
shutdown and refueling operations and (2) make temporary changes to the Limerick TS
related to anticipated transients without scram (ATWS) mitigation systems during power
production operation.
DATES: Submit comments by November 27, 2023. Request for a hearing or petitions
for leave to intervene must be filed by December 26, 2023.
ADDRESSES: You may submit comments by any of the following methods however, the
NRC encourages electronic comment submission through the Federal rulemaking
website:
Federal rulemaking website: Go to https://www.regulations.gov and search
for Docket ID NRC-2023-0182. Address questions about Docket IDs in Regulations.gov
to Stacy Schumann; telephone: 301-415-0624; email: Stacy.Schumann@nrc.gov. For technical questions, contact the individual listed in the For Further Information Contact
section of this document.
Mail comments to: Office of Administration, Mail Stop: TWFN-7-A60M, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Program
Management, Announcements and Editing Staff.
For additional direction on obtaining information and submitting comments, see
Obtaining Information and Submitting Comments in the SUPPLEMENTARY
INFORMATION section of this document.
FOR FURTHER INFORMATION CONTACT: Nicholas Smith, Office of Nuclear Reactor
Regulation, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001;
telephone: 301-415-2509; email: Nicholas.Smith@nrc.gov.
SUPPLEMENTARY INFORMATION:
I. Obtaining Information and Submitting Comments
A. Obtaining Information
Please refer to Docket ID NRC-2023-0182 when contacting the NRC about the
availability of information for this action. You may obtain publicly available information
related to this action by any of the following methods:
Federal Rulemaking Website: Go to https://www.regulations.gov and
search for Docket ID NRC-2023-0182.
NRCs Agencywide Documents Access and Management System
(ADAMS): You may obtain publicly available documents online in the ADAMS Public
Documents collection at https://www.nr c.gov/reading-rm/adams.html. To begin the
search, select Begin Web-based ADAMS Search. For problems with ADAMS, please
contact the NRCs Public Document Room (P DR) reference staff at 1-800-397-4209, at
301-415-4737, or by email to PDR.Resource@nrc.gov. The ADAMS accession number
2 for each document referenced (if it is available in ADAMS) is provided the first time that it
is mentioned in this document.
NRCs PDR: The PDR, where you may examine and order copies of publicly
available documents, is open by appointment. To make an appointment to visit the PDR,
please send an email to PDR.Resource@nrc.gov or call 1-800-397-4209 or 301-415-
4737, between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except
Federal holidays.
B. Submitting Comments
The NRC encourages electronic comment submission through the Federal
rulemaking website (https://www.regulations.gov). Please include Docket ID NRC-
2023-0182 in your comment submission.
The NRC cautions you not to include identifying or contact information that you
do not want to be publicly disclosed in your comment submission. The NRC will post all
comment submissions at https://www.regulat ions.gov as well as enter the comment
submissions into ADAMS. The NRC does not routinely edit comment submissions to
remove identifying or contact information.
If you are requesting or aggregating comments from other persons for
submission to the NRC, then you should inform those persons not to include identifying
or contact information that they do not want to be publicly disclosed in their comment
submission. Your request should state that the NRC does not routinely edit comment
submissions to remove such information before making the comment submissions
available to the public or entering the comment into ADAMS.
II. Introduction
The NRC is considering issuance of an amendment to Renewed Facility
Operating License Nos. NPF-39 and NPF-85, issued to Constellation Energy
3 Generation, LLC, for operation of the Limerick Generating Station, Units 1 and 2, located
in Montgomery County, Pennsylvania.
In accordance with section 50.90 of title 10 of the Code of Federal Regulations
(10 CFR) Application for amendment of license, construction permit, or early site
permit, Constellation Energy Generation, LLC (Constellation) requests an amendment
to Appendix A, Technical Specifications of Renewed Facility Operating License Nos.
NPF-39 and NPF-85 for Limerick Generating Station, Units 1 and 2, (Limerick)
respectively. The proposed TS changes will establish consistency with the Limerick
accident analysis and the plant design and s upport the installation of a digital
modification at Limerick during upcoming refueling outages. The proposed Limerick TS
changes will temporarily modify TS require ments affecting the mitigation of ATWS
events during power production operations, for example, removing the automatic
activation of the recirculating pumps for a period of 30 days prior to the refueling outage.
The TS requirements for ATWS systems to remain operational and conduct surveillance
on automatic activation systems during cold shutdown and refueling operations is
temporarily removed so that the systems can be converted from analog to digital.
Constellation has evaluated whether a significant hazards consideration is involved with
the proposed amendment by focusing on the three conditions set forth in 10 CFR 50.92,
Issuance of amendment, as discussed in the question responses.
Before any issuance of the proposed license amendment, the NRC will need to
make the findings required by the Atomic Energy Act of 1954, as amended (the Act), and
NRCs regulations.
The NRC has made a proposed determination that the license amendment
request involves no significant hazards consideration (NSHC). Under the NRCs
regulations in 10 CFR 50.92, this means that operation of the facility in accordance with
4 the proposed amendment would not (1) involve a significant increase in the probability or
consequences of an accident previously evaluated; or (2) create the possibility of a new
or different kind of accident from any accident previously evaluated; or (3) involve a
significant reduction in a margin of safety. As required by 10 CFR 50.91(a), the licensee
has provided its analysis of the issue of NSHC, as modified by NRC staff shown in
square brackets, which is presented as follows:
- 1. Does the proposed change involve a significant increase in the probability or
consequences of an accident previously evaluated?
Response: No.
[For changes related to cold shutdown and refuel operations]
The proposed changes revise TS requirements, actions, and testing during cold
shutdown and refueling to be consistent with the accident analysis and the plant design.
The proposed changes do not change any of the previously evaluated accidents in the
Updated Final Safety Analysis Report (UFSAR). None of the accidents previously
evaluated in [cold shutdown or refueling] assume a concurrent loss of offsite power or
automatic ECCS [emergency core cooling system] initiation. None of the accidents
previously evaluated in [cold shutdown and refueling] assume automatic starting of a
diesel generator or automatic sequencing of loads on the emergency busses. None of
the accidents previously evaluated in [cold shutdown or refueling] assume a manual reactor scram during refueling. None of the accidents previously evaluated assume the
reactor equipment interlocks are engaged with the reactor mode switch in Shutdown.
Therefore, elimination of these requirements from the TS will have no effect on the
likelihood of an accident previously evaluated nor their mitigation. Elimination of the
requirement to suspend core alterations with no operable ECCS subsystem in [cold
shutdown or refueling] will not affect the initiation of a draining event nor its mitigation.
5
[For changes related to power production operations]
The proposed changes establish a one-time Anticipated Transient Without Scram
Recirculation Pump Trip (ATWS-RPT) LCO [limiting condition for operation] Applicability
condition where ATWS-RPT is not required for 30 days under certain plant operational
constraints for both channels of ATWS-RPT instrumentation, as well as the applicability
and surveillance requirements for the associat ed Standby Liquid Control System (SLCS)
and the Reactor Water Cleanup (RWCU) isolation instrumentation. The ATWS-RPT
instrumentation, the SLCS, and RWCU instrumentation are mitigative systems and
components. As such, the proposed changes do not impact any accident or event
precursors. The probability of an ATWS event occurring does not increase due to this
proposed change.
Therefore proposed change[s related to power production operations] do not
involve a significant increase in the probability of an accident previously evaluated.
The consequences of the ATWS are not increased since the plant will be
operating at a reduced power level [with operational constraints] during the 30 days
when ATWS-RPT system is inoperable. The most severe/limiting ATWS events are
initiated by a pressurization transient. With SCRAM failure, a pressurization transient
can result in a large power spike which may be significantly higher than rated power.
The large increase in power exacerbates vessel pressurization.
[]
[Based on the plant operating at a lower power state with operational constraints,
and proposed risk mitigation actions being adopted as compensatory measures, there
will be no increase in consequences of this type of event. If the mitigation of an ATWS at
full power is comparable to that of the ATWS at this lower power state, with the
6 proposed compensatory measures, then there is no significant increase to the
consequences of the systems being changed.]
Therefore, proposed change[s related to ATWS mitigation systems in power
production operations] [will] not involve a significant increase in the consequences of an
accident previously evaluated.
- 2. Does the proposed change create the possibility of a new or different kind of
accident from any accident previously evaluated?
Response: No.
[For changes related to cold shutdown and refuel operations]
The proposed changes revise TS requirements, actions, and testing during cold
shutdown and refueling to establish consistency with the accident analysis and the plant
design. The proposed changes do not change the assumed design functions of the
affected systems in the applicable [cold shutdown and refuel operations]. The proposed
changes do not create any credible new accidents as the associated initiating events,
such as loss of power and a draining even t, are already considered in the licensing
basis.
[For changes related to power production operations]
The proposed changes establish a one-time ATWS-RPT LCO Applicability
condition where ATWS-RPT is not required for 30 days under certain plant operational
constraints for both channels of ATWS-RPT instrumentation, as well as the applicability
and surveillance requirements for the associated SLCS and the RWCU isolation
instrumentation. These changes impact a mitigating system for an existing transient. As
such, the unavailability of this mitigation system would not be considered an initiator of a
new or different kind of accident.
7 Therefore, the proposed changes do not create the possibility of a new or
different kind of accident from any previously evaluated.
- 3. Does the proposed change involve a significant reduction in a margin of
safety?
Response: No.
[For changes related to cold shutdown and refuel operations]
The proposed changes revise TS requirements, actions, and testing during cold
shutdown and refueling to be consistent with the accident analysis. The proposed
changes do not affect the analysis of any accident or event in the plants licensing basis.
The proposed changes do not alter any design basis or safety limit, or any controlling
numerical values for parameters established in the UFSAR or the license.
[For changes related to power production operations]
Based on a deterministic sensitivity analysis of the ATWS AOR [abnormal
occurrence report], the proposed changes will not cause a significant reduction in the
margin of safety provided that the plant is operated at a reduced thermal power level.
The use of available safety related and non-safety related equipment during the
30-day RRCS [Redundant Reactivity Control System] demolition period, at a reduced
power level [with operational constraints], will continue to protect the fuel, reactor, and
containment from failure during a postulated ATWS event. The fuel cladding barrier is
protected via adequate cooling and SLCS injection. The reactor coolant system
boundary is protected by ensuring compliance with the ASME emergency class pressure
limit of 120% of design pressure. The containment is protected by ensuring the
suppression pool pressure and temperature limits are met. Thus, there is no need for
any reduction in the margin of safety est ablished in the [Limerick] design and licensing
basis for the primary fission product barriers.
8 Therefore, the proposed changes do not involve a significant reduction in a
margin of safety.
Based on the above, Constellation concludes that the proposed amendments do
not involve a significant hazards consideration under the standards set forth in
10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is
justified.
The NRC staff has reviewed the licensees analysis, as modified by the NRC
staff, and based on this review, the three standards of 10 CFR 50.92(c) are satisfied.
Therefore, the NRC staff proposes to determine that the license amendment request
involves a NSHC.
The NRC is seeking public comments on this proposed determination that the
license amendment request involves no significant hazards consideration. Any
comments received within 30 days after the date of publication of this notice will be
considered in making any final determination.
Normally, the Commission will not iss ue the amendment until the expiration of
the 60-day notice period. However, if circumstances change during the notice period,
such that failure to act in a timely way would result, for example, in derating or shutdown
of the facility, the Commission may issue t he license amendment before the expiration of
the notice period, provided that its final determination is that the amendment involves no
significant hazards consideration. The final determination will consider all public and
State comments received. If the Commission takes action prior to the expiration of either
the comment period or the notice period, it will publish in the Federal Register a notice of
issuance. The Commission expects that the need to take this action will occur very
infrequently.
III. Opportunity to Request a Hearing and Petition for Leave to Intervene
9 Within 60 days after the date of publication of this notice, any person (petitioner)
whose interest may be affected by this action may file a request for a hearing and
petition for leave to intervene (petition) with respect to the action. Petitions shall be filed
in accordance with the Commissions Agency Rules of Practice and Procedure in
10 CFR part 2. Interested persons should consult 10 CFR 2.309. If a petition is filed, the
presiding officer will rule on the petition and, if appropriate, a notice of a hearing will be
issued.
Petitions must be filed no later than 60 days from the date of publication of this
notice in accordance with the filing instructions in the Electronic Submissions (E-Filing)
section of this document. Petitions and motions for leave to file new or amended
contentions that are filed after the deadline will not be entertained absent a
determination by the presiding officer that the filing demonstrates good cause by
satisfying the three factors in 10 CFR 2.309(c)(1)(i) through (iii).
If a hearing is requested and the Commission has not made a final determination
on the issue of no significant hazards consideration, the Commission will make a final
determination on the issue of no significant hazards consideration, which will serve to
establish when the hearing is held. If the final determination is that the amendment
request involves no significant hazards consideration, the Commission may issue the
amendment and make it immediately effective, notwithstanding the request for a
hearing. Any hearing would take place after issuance of the amendment. If the final
determination is that the amendment request involves a significant hazards
consideration, then any hearing held would take place before the issuance of the
amendment unless the Commission finds an imminent danger to the health or safety of
the public, in which case it will issue an appropriate order or rule under 10 CFR part 2.
10 A State, local governmental body, Federally recognized Indian Tribe, or
designated agency thereof, may submit a petition to the Commission to participate as a
party under 10 CFR 2.309(h) no later than 60 days from the date of publication of this
notice. Alternatively, a State, local governmental body, Federally recognized Indian
Tribe, or agency thereof may participate as a non-party under 10 CFR 2.315(c).
For information about filing a petition and about participation by a person not a
party under 10 CFR 2.315, see ADAMS Accession No. ML20340A053
(https://adamswebsearch2.nrc.gov/webSear ch2/main.jsp?AccessionNumber=ML20340A
053) and the NRCs public website at
https://www.nrc.gov/about-nrc/regulatory/ adjudicatory/hearing.html#participate.
IV. Electronic Submissions (E-Filing)
All documents filed in NRC adjudicatory proceedings, including documents filed
by an interested State, local governmental body, Federally recognized Indian Tribe, or
designated agency thereof that requests to participate under 10 CFR 2.315(c), must be
filed in accordance with 10 CFR 2.302. The E-Filing process requires participants to
submit and serve all adjudicatory documents over the internet, or in some cases, to mail
copies on electronic storage media, unless an exemption permitting an alternative filing
method, as further discussed, is granted. Detailed guidance on electronic submissions is
located in the Guidance for Electronic S ubmissions to the NRC (ADAMS Accession
No. ML13031A056) and the NRCs public website at https://www.nrc.gov/site-help/e-
submittals.html.
To comply with the procedural requirements of E-Filing, at least 10 days prior to
the filing deadline, the participant should contact the Office of the Secretary by email at
Hearing.Docket@nrc.gov, or by telephone at 301-415-1677, to (1) request a digital
identification (ID) certificate, which allows the participant (or its counsel or
11 representative) to digitally sign submissions and access the E-Filing system for any
proceeding in which it is participating; and (2) advise the Secretary that the participant
will be submitting a petition or other adjudicatory document (even in instances in which
the participant, or its counsel or representative, already holds an NRC-issued digital ID
certificate). Based upon this information, the Secretary will establish an electronic docket
for the proceeding if the Secretary has not already established an electronic docket.
Information about applying for a digital ID certificate is available on the NRCs
public website at https://www.nrc.gov/site-hel p/e-submittals/getting-started.html. After a
digital ID certificate is obtained and a docket created, the participant must submit
adjudicatory documents in Portable Document Format. Guidance on submissions is
available on the NRCs public website at http s://www.nrc.gov/site-help/electronic-sub-ref-
mat.html. A filing is considered complete at the time the document is submitted through
the NRCs E-Filing system. To be timely, an electronic filing must be submitted to the
E-Filing system no later than 11:59 p.m. ET on the due date. Upon receipt of a
transmission, the E-Filing system time-stamps the document and sends the submitter an
email confirming receipt of the document. The E-Filing system also distributes an email
that provides access to the document to the NRCs Office of the General Counsel and
any others who have advised the Office of the Secretary that they wish to participate in
the proceeding, so that the filer need not serve the document on those participants
separately. Therefore, applicants and other participants (or their counsel or
representative) must apply for and receive a digital ID certificate before adjudicatory
documents are filed to obtain access to the documents via the E-Filing system.
A person filing electronically using the NRCs adjudicatory E-Filing system may
seek assistance by contacting the NRCs Electronic Filing Help Desk through the
Contact Us link located on the NRCs public website at https://www.nrc.gov/site-help/e-
12 submittals.html, by email to MSHD.Resource@nrc.gov, or by a toll-free call at
1-866-672-7640. The NRC Electronic Filing Help Desk is available between 9 a.m. and
6 p.m., ET, Monday through Friday, except Federal holidays.
Participants who believe that they have good cause for not submitting documents
electronically must file an exemption request, in accordance with 10 CFR 2.302(g), with
their initial paper filing stating why there is good cause for not filing electronically and
requesting authorization to continue to submit documents in paper format. Such filings
must be submitted in accordance with 10 CFR 2.302(b)-(d). Participants filing
adjudicatory documents in this manner are responsible for serving their documents on all
other participants. Participants granted an exemption under 10 CFR 2.302(g)(2) must
still meet the electronic formatting requirement in 10 CFR 2.302(g)(1), unless the
participant also seeks and is granted an exemption from 10 CFR 2.302(g)(1).
Documents submitted in adjudicatory proceedings will appear in the NRCs
electronic hearing docket, which is publicly available at https://adams.nrc.gov/ehd,
unless excluded pursuant to an order of the presiding officer. If you do not have an NRC-
issued digital ID certificate as previously described, click cancel when the link requests
certificates and you will be automatically directed to the NRCs electronic hearing
dockets where you will be able to access any publicly available documents in a particular
hearing docket. Participants are requested not to include personal privacy information
such as social security numbers, home addresses, or personal phone numbers in their
filings unless an NRC regulation or other law requires submission of such information.
With respect to copyrighted works, except for limited excerpts that serve the purpose of
the adjudicatory filings and would constitute a Fair Use application, participants should
not include copyrighted materials in their submission.
For further details with respect to this action, see the application for license
13 amendment dated February 17, 2023 (ADAMS Accession No. ML23052A023), as
supplemented on July 21, 2023 (ADAMS Accession No. ML23202A219), July 31, 2023
(ADAMS Accession No. ML23212B105), and August 16, 2023 (ADAMS Accession No.
Attorney for licensee : Jason Zorn, Associate General Counsel, Constellation Energy
Generation, LLC, 101 Constitution Ave, NW, Suite 400 East, Washington, DC 20001.
NRC Branch Chief: Hipolito Gonzalez.
Dated: October 24, 2023.
For the Nuclear Regulatory Commission.
/RA/
Hipolito Gonzalez, Chief, Plant Licensing Branch I, Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation.
14