JAFP-24-0045, Supplemental Information for License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4, and Administrative Changes to the Technical Specifications

Supplemental Information for License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4, and Administrative Changes to the Technical Specifications

ML24264A140
Person / Time
Site:	FitzPatrick
Issue date:	09/20/2024
From:	Para W Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
JAFP-24-0045
Download: ML24264A140 (1)

Text

200 Energy Way Kennett Square, PA 19348 www.constellation.com

JAFP-24-0045

10 CFR 50.90

September 20, 2024

United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

Supplemental Information for License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules," Revision 4, and Administrative Changes to the Technical Specifications

Reference:

Letter from D. Gudger (Constellation Energy Generation, LLC) to U.S. Nuclear Regulatory Commission, License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules," Revision 4, and Administrative Changes to the Technical Specifications, JAFP-23-0065 (ML23348A154), dated December 14, 2023

By letter dated December 14, 2023 (Reference), Constellation Energy Generation, LLC (CEG) requested a change to the Technical Specification (TS) in accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit."

By email dated September 11, 2024, Nuclear Regulatory Commission (NRC) identified an editorial error in Attachments 2 and 3 of the Reference. The specific error was that the proposed TS page 3.0-2 did not reflect the intended change made in TSTF-529. As stated in Attachment 1 of the Reference, CEG is not proposing any variations from the TS changes described in the TSTF-529.

New proposed TS pages are provided by this letter to correct the error in the proposed TS pages in the Reference.

of this supplement replaces the marked-up TS Page 3.0-2 in Attachment 2 of the Reference, in its entirety; and Attachment 2 of this supplement replaces the clean TS Page 3.0-2 in of the Reference, in its entirety.

CEG has reviewed the information supporting the No Significant Hazards Consideration and the Environmental Consideration that was previously pr ovided to the NRC in the Reference. The revised TS page provided in this submittal does not affect the conclusion that the proposed license amendment does not involve a significant hazards consideration. revised TS page also does not affect the conclusion that neither an environm ental impact statement nor an environmental assessment need be prepared in support of the proposed amendment.

U.S. Nuclear Regulatory Commission Supplemental Information for License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules," and Administrative Changes to the Technical Specifications Docket No. 50-333 September 20, 2024 Page 2

This letter contains no new regulatory commitments.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

CEG is transmitting a copy of this letter and its attachments to the designated State Official.

Should you have any questions concerning this submittal, please contact Abul Hasanat at (267) 533-5733.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the September 20, 2024.

Respectfully,

Wendi E. Para Senior Manager - Licensing Constellation Energy Generation, LLC

Attachments:

1. Mark-up Technical Specification Page

2. Clean Technical Specification Page

cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, JAF USNRC Project Manager, JAF A. L. Peterson, NYSERDA ATTACHMENT 1

Supplemental Information for License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules," and Administrative Changes to the Technical Specifications

James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59

MARK-UP TECHNICAL SPECIFICATION PAGE

3.0-2

LCO Applicability 3.0

3.0 LCO APPLICABILITY

LCO 3.0.4 b. After performance of a risk assessment addressing inoperable (continued) systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; ( exceptions to this Specification are stated in the individual Specifications; ) ; or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered.

Only the support system LCO ACTIONS are required to be entered.

This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.12, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

(continued)

JAFNPP 3.0-2 Amendment 337 ATTACHMENT 2

Supplemental Information for License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, "Clarify Use and Application Rules," and Administrative Changes to the Technical Specifications

James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59

CLEAN TECHNICAL SPECIFICATION PAGE

3.0-2

LCO Applicability 3.0

3.0 LCO APPLICABILITY

LCO 3.0.4 b. After performance of a risk assessment addressing inoperable (continued) systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered.

Only the support system LCO ACTIONS are required to be entered.

This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.12, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

(continued)

JAFNPP 3.0-2 Amendment