ML24276A133

Issuance of Amendment No. 357 Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision-4, and Administrative Changes

ML24276A133
Person / Time
Site:	FitzPatrick  (DPR-059)
Issue date:	10/17/2024
From:	James Kim Plant Licensing Branch 1
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
Poole J
References
EPID L-2023-LLA-0173
Download: ML24276A133 (42)

Text

October 17, 2024 David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - ISSUANCE OF AMENDMENT NO. 357 RE: REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-529, CLARIFY USE AND APPLICATION RULES, REVISION-4, AND ADMINISTRATIVE CHANGES (EPID L-2023-LLA-0173)

Dear David Rhoades:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 357 to Renewed Facility Operating License No. DPR-59 for the James A. FitzPatrick Nuclear Power Plant. The amendment consists of changes to the technical specifications (TSs) in response to your application dated December 14, 2023, as supplemented by letter dated September 20, 2024.

The amendment revises the TS requirements in Section1.3 regarding Completion Times and Section 3.0 regarding Limiting Condition for Operation and Surveillance Requirement usage.

These changes are consistent with the NRC-approved Technical Specification Task Force (TSTF) Traveler TSTF-529, Revision 4, Clarify Use and Application Rules. Additionally, the amendment makes several administrative changes to the TS.

A copy of our related Safety Evaluation is also enclosed. The notice of issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

James S. Kim, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosures:

1. Amendment No. 357 to DPR-59

2. Safety Evaluation cc: Listserv CONSTELLATION FITZPATRICK, LLC AND CONSTELLATION ENERGY GENERATION, LLC DOCKET NO. 50-333 JAMES A. FITZPATRICK NUCLEAR POWER PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 357 Renewed Facility Operating License No. DPR-59

1.

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

A.

The application for amendment by Constellation FitzPatrick, LLC and Constellation Energy Generation, LLC (collectively, the licensees), dated December 14, 2023, as supplemented by letter dated September 20, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-59 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 357, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION Hipólito 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: October 17, 2024 HIPOLITO GONZALEZ Digitally signed by HIPOLITO GONZALEZ Date: 2024.10.17 11:13:06 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 357 JAMES A. FITZPATRICK NUCLEAR POWER PLANT RENEWED FACILITY OPERATING LICENSE NO. DPR-59 DOCKET NO. 50-333 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 marginal lines indicating the areas of change.

Remove Page Insert Page Page 3 Page 3 Replace the following page of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Page Insert Page 1.3-1 1.3-1 1.3-2 1.3-2 3.0-2 3.0-2 3.0-5 3.0-5 3.3.3.2-2 3.3.3.2-2 3.3.6.1-4 3.3.6.1-4 3.3.6.1-5 3.3.6.1-5 3.5.1-1 3.5.1-1 3.5.1-4 3.5.1-4 3.5.3-1 3.5.3-1 3.5.3-2 3.5.3-2 3.5.3-3 3.5.3-3 3.6.1.3-8 3.6.1.3-8 3.6.4.1-1 3.6.4.1-1 3.7.4-3 3.7.4-3 3.8.1-5 3.8.1-5 3.8.1-6 3.8.1-6 3.8.3-2 3.8.3-2 3.8.3-3 3.8.3-3 3.8.4-3 3.8.4-3 3.8.5-2 3.8.5-2 3.8.6-2 3.8.6-2 3.8.6-3 3.8.6-3 Amendment 357 Renewed License No. DPR-59 (3)

Constellation Energy Generation, LLC, 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)

Constellation Energy Generation, LLC, 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 without restriction to chemical or physical form, for sample analysis or instrument calibration; or associated with radioactive apparatus, components or tools.

(5)

Constellation Energy Generation, LLC, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C.

This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; 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 steady state reactor core power levels not in excess of 2536 megawatts (thermal).

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 357, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times JAFNPP 1.3-1 Amendment 357 PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the plant. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g.,

inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the plant is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources - Operating," Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the plant is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the (continued)

Completion Times 1.3 1.3 Completion Times JAFNPP 1.3-2 Amendment 357 associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a.

Must exist concurrent with the first inoperability; and

b.

Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a.

The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or

b.

The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extension does not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery..."

DESCRIPTION (continued)

(continued)

LCO Applicability 3.0 3.0 LCO APPLICABILITY JAFNPP 3.0-2 Amendment 357 LCO 3.0.4 (continued)

b.

After performance of a risk assessment addressing inoperable 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)

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY JAFNPP 3.0-5 Amendment 357 SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per..."

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

Remote Shutdown System 3.3.3.2 JAFNPP 3.3.3.2-2 Amendment 357 SURVEILLANCE REQUIREMENTS

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When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> SURVEILLANCE FREQUENCY SR 3.3.3.2.1 Perform CHANNEL CHECK for each required instrumentation channel that is normally energized.

In accordance with the Surveillance Frequency Control Program SR 3.3.3.2.2 Verify each required control circuit and transfer switch is capable of performing the intended function.

In accordance with the Surveillance Frequency Control Program SR 3.3.3.2.3 Perform CHANEL CALIBRATION for each required instrumentation channel.

In accordance with the Surveillance Frequency Control Program

Primary Containment Isolation Instrumentation 3.3.6.1 JAFNPP 3.3.6.1-4 Amendment 357 SURVEILLANCE REQUIREMENTS

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1. Refer to Table 3.3.6.1-1 to determine which SRs apply for each Primary Containment Isolation Function.

2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed as follows: (a) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions 2.d, 2.g, 7.a, and 7.b; and (b) for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for Functions other than 2.d, 2.g, 7.a, and 7.b provided the associated Function maintains isolation capability.

SURVEILLANCE FREQUENCY SR 3.3.6.1.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.2 Perform CHANNEL FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.3

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For Functions 1.f and 2.f, radiation detectors are excluded.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program (continued)

Primary Containment Isolation Instrumentation 3.3.6.1 JAFNPP 3.3.6.1-5 Amendment 357 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.6.1.4 Calibrate the trip units.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.5 Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.6 Calibrate the radiation detectors.

In accordance with the Surveillance Frequency Control Program SR 3.3.6.1.7 Perform LOGIC SYSTEM FUNCTIONAL TEST.

In accordance with the Surveillance Frequency Control Program

ECCS - Operating 3.5.1 JAFNPP 3.5.1-1 Amendment 357 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC)

SYSTEM 3.5.1 ECCS-Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.

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Low pressure coolant injection (LPCI) subsystems may be considered OPERABLE during alignment and operation for decay heat removal with reactor steam dome pressure less than the Residual Heat Removal (RHR) cut in permissive pressure in MODE 3, if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY:

MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.

ACTIONS

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LCO 3.0.4.b is not applicable to High Pressure Coolant Injection (HPCI).

CONDITION REQUIRED ACTION COMPLETION TIME A.

One low pressure ECCS injection/spray subsystem inoperable.

OR One low pressure coolant injection (LPCI) pump in both LPCI subsystems inoperable.

A.1 Restore low pressure ECCS injection/spray subsystem(s) to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B.

Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in Mode 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours (continued)

ECCS - Operating 3.5.1 JAFNPP 3.5.1-4 Amendment 357 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.2 Verify each ECCS injection/spray subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.3 Verify ADS pneumatic supply header pressure is 95 psig.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.4 Verify the RHR System cross tie valves are closed and power is removed from the electrical valve operator.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.5 Cycle open and closed each LPCI motor operated valve independent power supply battery charger AC input breaker and verify each LPCI inverter output voltage is 576 V and 624 V while supplying the respective bus.

In accordance with the Surveillance Frequency Control Program (continued)

RCIC System 3.5.3 JAFNPP 3.5.3-1 Amendment 357 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC)

SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE APPLICABILITY:

MODE 1, MODES 2 and 3 with reactor steam dome pressure > 150 psig.

ACTIONS

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LCO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION COMPLETION TIME A.

RCIC System inoperable.

A.1 Verify by administrative means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System to OPERABLE status.

Immediately 14 days OR In accordance with the Risk Informed Completion Time Program B.

Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Reduce reactor steam dome pressure to 150 psig.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours

RCIC System 3.5.3 JAFNPP 3.5.3-2 Amendment 357 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 Verify the RCIC System piping is filled with water from the pump discharge valve to the injection valve.

In accordance with the Surveillance Frequency Control Program SR 3.5.3.2 Verify each RCIC System manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program SR 3.5.3.3

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Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 1040 psig and 970 psig, the RCIC pump can develop a flow rate 400 gpm against a system head corresponding to reactor pressure.

In accordance with the Surveillance Frequency Control Program SR 3.5.3.4

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Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure 165 psig, the RCIC pump can develop a flow rate 400 gpm against a system head corresponding to reactor pressure.

In accordance with the Surveillance Frequency Control Program (continued)

RCIC System 3.5.3 JAFNPP 3.5.3-3 Amendment 357 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.3.5

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1. Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.

2. Vessel injection may be excluded.

Verify the RCIC System actuates on an actual or simulated automatic initiation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

In accordance with the Surveillance Frequency Control Program

PCIVs 3.6.1.3 JAFNPP 3.6.1.3-8 Amendment 357 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.3.3

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1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. Not required to be met for PCIVs that are open under administrative controls.

Verify each primary containment manual isolation valve and blind flange that is located inside primary containment and not locked, sealed or otherwise secured and is required to be closed during accident conditions is closed.

Prior to entering MODE 2 or 3 from MODE 4 if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days SR 3.6.1.3.4 Verify continuity of the traversing incore probe (TIP) shear isolation valve explosive charge.

In accordance with the Surveillance Frequency Control Program SR 3.6.1.3.5 Verify the isolation time of each power operated, automatic PCIV, except for MSIVs, is within limits.

In accordance with the INSERVICE TESTING PROGRAM SR 3.6.1.3.6 Verify the isolation time of each MSIV is 3 seconds and 5 seconds.

In accordance with the INSERVICE TESTING PROGRAM (continued)

Secondary Containment 3.6.4.1 JAFNPP 3.6.4.1-1 Amendment 357 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment.

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Recently irradiated is defined for Technical Specification 3.6.4.1 as fuel assemblies which have occupied part of a critical reactor core within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Secondary containment inoperable in MODE 1, 2, or 3.

A.1 Restore secondary containment to OPERABLE status.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B.

Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours C.

Secondary containment inoperable during movement of recently irradiated fuel assemblies in the secondary containment.

C.1

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LCO 3.0.3 is not applicable.

Suspend movement of recently irradiated fuel assemblies in the secondary containment.

Immediately

Control Room AC System 3.7.4 JAFNPP 3.7.4-3 Amendment 357 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify each control room AC subsystem has the capability to remove the assumed heat load.

In accordance with the Surveillance Frequency Control Program

AC Sources - Operating 3.8.1 JAFNPP 3.8.1-5 Amendment 357 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.2

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All EDG subsystem starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

Verify each EDG subsystem starts from standby conditions, force parallels, and achieves:

a.

In 10 seconds, voltage 3900 V and frequency 58.8 Hz; and

b.

Steady state voltage 3900 V and 4400 V and frequency 58.8 Hz and 61.2 Hz.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.3

- - - - - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - - - -

1.

EDG loading may include gradual loading as recommended by the manufacturer.

2.

Momentary transients outside the load range do not invalidate this test.

3.

This Surveillance shall be conducted on only one EDG subsystem at a time.

4.

This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2.

Verify each EDG subsystem is paralleled with normal, reserve, or backfeed power and each EDG is loaded and operates for 60 minutes at a load 2340 kW and 2600 kW.

In accordance with the Surveillance Frequency Control Program (continued)

AC Sources - Operating 3.8.1 JAFNPP 3.8.1-6 Amendment 357 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.4 Verify each day tank contains 327 gal of fuel oil.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from each day tank In accordance with the Surveillance Frequency Control Program SR 3.8.1.6 Verify that each EDG fuel oil transfer system operates to automatically transfer fuel oil from its storage tank to the associated day tank.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.7

- - - - - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - - - - - -

Only required to be met for each offsite circuit that is not energizing its respective 4.16 kV emergency bus.

Verify automatic and manual transfer of plant power supply from the normal station service transformer to each offsite circuit.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.8

- - - - - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - - - - - - -

If performance with EDG subsystem paralleled with normal, reserve, or backfeed power, it shall be performed within the power factor limit. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition, the power factor shall be maintained as close to the limit as practicable.

Verify each EDG subsystem rejects a load greater than or equal to its associated single largest post-accident load, and following load rejection, the frequency is 66.75 Hz.

In accordance with the Surveillance Frequency Control Program (continued)

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 JAFNPP 3.8.3-2 Amendment 357 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more EDGs with new fuel oil properties not within limits.

D.1 Restore stored fuel oil properties to within limit.

30 days E. One or more EDGs with required starting air receiver pressure <

150 psig and 110 psig.

E.1 Restore required starting air receiver pressure to within limits.

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> F. Requires Action and associated Completion Time of Condition A, B, C, D, or E not met.

OR One or more EDGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other then condition A, B, C, D, or E.

F.1 Declare associated EDG inoperable.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains a 7 day supply of fuel.

In accordance with the Surveillance Frequency Control Program (continued)

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 JAFNPP 3.8.3-3 Amendment 357 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.3.2 Verify lube oil inventory of each EDG is a 7 day supply.

In accordance with the Surveillance Frequency Control Program SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the diesel Fuel Oil Testing Program.

In accordance with the Diesel Fuel Oil Testing Program SR 3.8.3.4 Verify Each EDG required air start receiver pressure is 150 psig.

In accordance with the Surveillance Frequency Control Program SR 3.8.3.5 Check for and remove accumulated water from each fuel oil storage tank.

In accordance with the Surveillance Frequency Control Program

DC Sources - Operating 3.8.4 JAFNPP 3.8.4-3 Amendment 357 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage on float charge is:

a.

127.8 VDC for 125 VDC batteries, and

b.

396.2 VDC for 419 VDC LPCI MOV independent power supply batteries.

In accordance with the Surveillance Frequency Control Program SR 3.8.4.2 Verify each 125 VDC battery charger supplies 270 amps at 128 VDC for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

OR Verify each 125 VDC battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

In accordance with the Surveillance Frequency Control Program SR 3.8.4.3

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This Surveillance shall not normally be performed in MODE 1, 2, or 3 for the 125 VDC batteries. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test or a modified performance discharge test.

In accordance with the Surveillance Frequency Control Program (continued)

DC Sources - Shutdown 3.8.5 JAFNPP 3.8.5-2 Amendment 357 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.2.3 Initiate action to restore required DC electrical power subsystem to OPERABLE status.

Immediately SURVEILLANCE REQUREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1

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The following SRs are not required to be performed: SR 3.8.4.2, SR 3.8.4.3, and SR 3.8.4.4.

For DC electrical power subsystem required to be OPERABLE the fallowing SRs are applicable:

SR 3.8.4.1, SR 3.8.4.2, SR 3.8.4.3, and SR 3.8.4.4.

In accordance with applicable SRs

Battery Cell Parameters 3.8.6 JAFNPP 3.8.6-2 Amendment 357 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.3 Restore battery cell parameters to Category A and B limits of Table 3.8.6-1.

31 days B. Required Action and associated Completion Time of Condition A not met.

OR One or more batteries with average electrolyte temperature of the representative cells not within limits.

OR One or more batteries with one or more battery cell parameters not within Category C limits.

B.1 Declare associated battery inoperable.

Immediately SURVEILLANCE REQUREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 Verify battery cell parameters meet Table 3.8.6-1 Category A limits.

In accordance with the Surveillance Frequency Control Program (continued)

Battery Cell Parameters 3.8.6 JAFNPP 3.8.6-3 Amendment 357 SURVEILLANCE REQUREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.2 Verify battery cell parameters meet Table 3.8.6-1 Category B limits.

In accordance with the Surveillance Frequency Control Program SR 3.8.6.2 Verify average electrolyte temperature of representative cells is 65°F for each 125 VDC battery, and 50°F for each 419 VDC LPCI MOV independent power supply battery.

In accordance with the Surveillance Frequency Control Program

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 357 CONSTELLATION FITZPATRICK, LLC CONSTELLATION ENERGY GENERATION, LLC DOCKET NO. 50-333 JAMES A. FITZPATRICK NUCLEAR POWER PLANT TO RENEWED FACILITY OPERATING LICENSE NO. DPR-59

1.0 INTRODUCTION

By letter dated December 14, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23348A154), as supplemented by letter dated September 20, 2024 (ML24264A140), Constellation Energy Generation, LLC, the licensee for the James A.

FitzPatrick Nuclear Power Plant (JAF) proposed adoption of changes to the Standard Technical Specifications (STS) approved in TSTF-529, Revision 4, Clarify Use and Application Rules into the JAF Technical Specifications (TSs). TSTF-529, Revision 4, made changes to STS Section 1.3, STS LCO [limiting condition for operation] 3.0.4, and SR 3.0.3. TSTF-529, Revision 4 was approved by the NRC by letter dated April 21, 2016 (ML16060A441). The licensee also proposed deletion of outdated footnotes and associated footnote indicators along with editorial changes for some letters from uppercase to lower case to match formatting conventions in the rest of the TS.

The proposed changes would revise JAF TS, Sections 1.3, Completion Times, and 3.0, LCO

[limiting condition for operation] Applicability and SR [surveillance requirement] Applicability.

The proposed changes would also clarify and expand the use and application of the JAF TS usage rules.

The supplemental letter dated September 20, 2024, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staffs original proposed no significant hazards consideration determination as published in the Federal Register on February 20, 2024 (89 FR 12875).

2.0 REGULATORY EVALUATION

2.1 Description of Subject TS Sections Limiting conditions for operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The actions associated with an LCO state conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated condition are required action(s) and completion time(s).

JAF TS Section 1.3, Completion Times, currently describes completion times as follows:

The completion time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time.

An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition.

Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.

JAF LCO 3.0.1 through LCO 3.0.9 establish the general requirements applicable to all specifications and apply at all times, unless otherwise stated. Similarly, SR 3.0.1 through SR 3.0.4 establish the general requirements for surveillances that are applicable to all specifications and apply at all times, unless otherwise stated.

2.2 Description of TS Changes The proposed change will revise the JAF TS, Sections 1.3, Completion Times, and 3.0, LCO Applicability and SR Applicability. The proposed changes are described in more detail below.

2.2.1 Proposed Changes to Time of Discovery TS Section 1.3, Description, currently states, in part, the following (with emphasis added on time of):

The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

TS Section 1.3, Description, also currently states, in part, the following (with emphasis added on time of):

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition.

One of the proposed TS Section 1.3 changes would delete time of from the previous statements to make them read as follows:

The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

[]

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition.

The adequacy of this change is discussed in Section 3.1.1.1.

2.2.2 Proposed Addition to Time of Discovery The licensee proposed to add the following paragraph to Section 1.3 of the TS under

==

Description:==

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The otherwise specified exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time.

For example, LCO 3.8.1, AC Sources - Operating, Required Action B.2, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable. The Completion Time states, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s). In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

The adequacy of this change is discussed in Section 3.1.1.2.

2.2.3 Proposed Addition of Unless Otherwise Specified The licensee proposed adding the phrase in bold text to the end of the following two statements at the top of TS page 1.3-2:

When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

and The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

The adequacy of this change is discussed in Section 3.1.1.3.

2.2.4 Proposed Changes to LCO 3.0.4 JAF TS LCO 3.0.4 currently states:

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

After performance of a risk assessment addressing inoperable 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.

The licensee proposed to clarify the b. statement above by placing the statement regarding exceptions in parenthesis. The proposed TS LCO 3.0.4 would state the following:

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

After performance of a risk assessment addressing inoperable 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.

The adequacy of this change is discussed in Section 3.1.2.

2.2.5 Proposed Changes to JAF TS SR 3.0.3 TS SR 3.0.3 currently states the following:

If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

The licensee proposed adding the sentence in bold text to SR 3.0.3 which would read as below:

If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

The adequacy of this change is discussed in Section 3.1.3.

2.2.6 Proposed editorial changes and deletion of expired footnotes The licensee described the proposed deletion of expired footnotes and asterisks used as indicators related to Amendment 342 In Section 3 of the LAR. Likewise in Section 3 of the LAR the licensee described the proposed change of header text from RCIC SYSTEM to RCIC System. The review of the proposed changes is discussed in Section 3.1.4.

2.3 Regulatory Requirements, Licensing Information, Guidance Documents The NRC staff considered the following regulatory requirements, guidance, and licensing information during its review of the proposed changes.

Under 10 CFR 50.36(c), TSs are required to include items in the following categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; (5) administrative controls; (6) decommissioning; (7) initial notification; and (8) written reports.

Section 50.36(c)(2) of 10 CFR states that:

Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. When a limiting condition for operation of any process step in the system of a fuel reprocessing plant is not met, the licensee shall shut down that part of the operation or follow any remedial action permitted by the technical specifications until the condition can be met.

Section 50.36(c)(3) of 10 CFR states that Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The NRC staffs guidance for the review of the TSs is in NUREG-0800, Standard Review Plan

[SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Chapter 16, Technical Specifications, Revision 3, dated March 2010 (ML100351425). As described therein, as part of the regulatory standardization effort, the staff has prepared improved STSs for each of the LWR nuclear steam supply systems and associated balance-of-plant equipment systems. The licensees proposed amendment is based on TSTF-529, Revision 4, which is a change to the improved STSs that the NRC approved in April 2016 (ML16060A440). The staffs review includes consideration of whether the proposed changes are consistent with the NRC-approved TSTF-529, Revision 4. Special attention is given to TS provisions that depart from the improved STSs, as modified by NRC-approved TSTF travelers, to determine whether proposed differences are justified by uniqueness in plant design or other considerations so that 10 CFR 50.36 is met. In addition, the guidance states that comparing the change to previous STSs can help clarify the TS intent.

3.0 TECHNICAL EVALUATION

During the review of TSTF-529, Revision 4, the NRC staff considered generally the guidance on acceptance criteria of the SRP sections described in Section 2.3 of this safety evaluation, and, in particular, the acceptance criteria in Chapter 16, Technical Specifications, of NUREG-0800, Revision 3. The NRC staff evaluated the proposed changes to the JAF TS against the STS, as modified by approved TSTF-529, Revision 4 changes, as well as the requirements of 10 CFR 50.36(c).

3.1 Requested Changes 3.1.1 Proposed Changes to Section 1.3, Completion Times 3.1.1.1 Proposed Changes to Time of Discovery The only mention of the term time of discovery in relation to completion times is in TS Section 1.3 (quoted in Section 2.2.1 of this SE). Throughout the TS, the term discovery is used to describe the point in time that it is recognized that the requirements of an LCO are not met. For example, TS LCO 3.0.2 states in part, Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. In addition, the Bases to LCO 3.0.2, state, in part, LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met.

The proposed TS Section 1.3 would delete time of from the previous statements. This deletion was approved for the STS in TSTF-529. The NRC staff finds the proposed change acceptable because it makes Section 1.3 consistent with the language used throughout the rest of the TS.

This provides clarity to the term discovery, and therefore provides a clear and objective application of the TSs required actions and associated completion times. The change is editorial since it does not change the requirements currently in the TSs. The change also adopts an approved TSTF-529 change to the JAF TS. Therefore, the NRC Staff finds the proposed change acceptable.

3.1.1.2 Proposed Addition to Time of Discovery The proposed addition of the paragraph quoted in Section 2.2.2 of this SE is a TSTF-529 approved change.

The operating shift crew is responsible for overall control of facility operation. As part of that responsibility, the operating shift crew must be aware of the status of the plant and condition of structures, systems and components (SSCs). This includes status of degraded or nonconforming conditions that may affect plant operation. Therefore, the proposed change simply augments the NRC staffs expectation that a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met, and a Condition is entered. The phrase and an ACTIONS Condition is entered in the above proposed insertion, is necessary to accommodate circumstances in which LCO 3.0.6 allows an LCO to not be met without entry into the Conditions. In those circumstances, a Completion Time does not begin. In addition, an example is added to the proposed insertion in order to explain the concept presented.

The NRC staff finds the proposed change acceptable since it clarifies senior reactor operators responsibilities and the allowances of LCO 3.0.6, and therefore, provides a clear and objective application of the TS Required Actions and associated Completion Times and it adopts an approved TSTF-529 change to the JAF TS.

3.1.1.3 Proposed Addition of Unless Otherwise Specified The phrase, unless otherwise specified, in TS Section 1.3, refers to those instances in which the TS LCOs define the start of the Completion Time as different from discovery. For example, TS 3.8.1, AC Sources - Operating, Required Action B.2, calls for declaring required feature(s) supported by an inoperable diesel generator inoperable when the redundant required feature(s) are inoperable. The Completion Time states, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s). In this case, the Completion Time does not begin until the conditions in the Completion Time are satisfied.

The licensee proposed adding the phrase unless otherwise specified. to the paragraphs described in Section 2.2.3 of this SE. The addition of the phrase unless otherwise specified acknowledges that there are instances, as indicated in the individual TSs, when the completion time does not start at discovery. These exceptions are varied, such as when a Required Action Note or Surveillance Requirement Note provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins.

Should the time allowance in the Note be exceeded, the Completion Time begins at that point.

The NRC staff approved the addition of the phrase to the STS in TSTF-529. The NRC staff finds the proposed change to JAF TS acceptable since it clarifies that there are exceptions and therefore provides a clear and objective application of the TS Required Actions and associated Completion Times and it adopts an approved TSTF-529 change to the JAF TS.

3.1.2 Proposed Changes to LCO 3.0.4 As stated in Section 2.2.4 of this SE, the current TS LCO 3.0.4 contains three options, (a, b, and c). Paragraph a ends with a semicolon followed by an or and paragraph b ends with a semicolon followed by an or.

The LCO 3.0.4.b, After performance of a risk assessment stated in the individual Specifications; or, could lead to operator misinterpretation. Operators could misapply this statement by believing the or applies to the phrase regarding exceptions and that LCO 3.0.4.a, b, and c apply concurrently.

The licensee proposed to clarify this sentence by placing the statement regarding exceptions in parenthesis. The proposed TS LCO 3.0.4 would state the following: After performance of a risk assessment if appropriate (exceptions to this specification are stated in the individual specifications); or.

The NRC staff finds that the change is editorial since it does not change the requirements currently in the TSs. Prior to approval of TSTF -529, LCO 3.0.4.b ended with a comma followed by an or. The NRC staff approved placing the statement regarding exceptions in parenthesis and replacing the ending comma with a semicolon in the STS in TSTF-529. The NRC staff finds the proposed change acceptable since it removes potential for misapplication of LCO 3.0.4 allowances, and therefore, provides a clear and objective application of the TS Required Actions and it adopts an approved TSTF-529 change to the JAF TS.

3.1.3 Proposed Changes to SR 3.0.3 The NRC has typically interpreted SR 3.0.3, which is quoted in Section 2.2.5 of this SE, as inapplicable to SRs that have never been previously performed. This is because the allowance provided by SR 3.0.3 is based on the fact that the SR was satisfactorily met in the past and the most probable result of performing the SR is the verification of conformance with the requirements. Therefore, there is reasonable expectation the SR will be met when performed.

However, the NRC staff recognizes that there are instances in which an SR may not have been performed in the past, but there is still a reasonable expectation the SR will be met when performed. For example, an SR requires testing of a relay contact. A licensee finds the relay contact has never been tested as required in accordance with a particular SR. That licensee, however, finds there is a reasonable expectation the SR will be met when performed because the subject relay contact has been tested by another SR or historical operation of the subject relay contact has been successful.

The delay period allowed by TS SR 3.0.3 offers adequate time to complete SRs that have been missed. In addition, this delay period permits the completion of an SR before complying with required actions or other remedial measures that might preclude completion of the SR. The NRC staff finds the application of the delay period provided by TS SR 3.0.3 acceptable for use on SRs that have never been performed so as long as licensees can provide an adequate determination of reasonable expectation the SR will be met when performed.

The licensee proposed adding the sentence to SR 3.0.3 as described in in Section 2.2.5 of this SE. The NRC staff approved adding the sentence to STS SR 3.0.3 in TSTF-529. When making a determination of reasonable expectation that the SR will be met when performed, licensees should consider many factors. These factors include, but are not limited to, things such as the period of time since the SR was last performed, or whether the SR, or a portion thereof, has ever been performed, and many other indications, tests, or activities that might support the expectation that the SR will be met when performed. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation an SR will be met when performed should increase based on the length of time since the last performance of the SR. If the SR has been performed recently, a review of the SR history and equipment performance may be sufficient to support a reasonable expectation that the SR will be met when performed. For SRs that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is capable of performing its specified safety function(s). The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

The proposed change, which expands the scope of SR 3.0.3 to SRs that have never been performed, is acceptable because it requires there to be an adequate determination of a reasonable expectation the SR will be met when performed. In addition, the proposed change augments plant safety since it could prevent unnecessary shutdowns by providing adequate time to complete SRs that have never been performed but are likely to achieve satisfactory results. Finally, addition of the sentence adopts an approved TSTF-529 change to the JAF TS.

3.1.4 Editorial deletions and changes Amendment No. 342 to JAF TS added footnotes to extend the completion time of condition A of TS 3.6.4.1 and modify SR frequencies to allow continued operation while the A RHR pump was repaired. The repairs were completed and the footnotes are expired. The staff reviewed the proposed deletions and determined since they are expired, the footnotes no longer affect how the TS are used, therefore the proposed deletions are acceptable editorial changes. Likewise, the staff reviewed the proposed changes of header text from RCIC SYSTEM to RCIC System and determined the changes are editorial and acceptable.

3.2 Technical Conclusion As described in Section 2.3 of this SE, the regulations contained in 10 CFR 50.36 require that TS include items in specified categories, including LCOs and SRs. The proposed changes modify the LCOs, conditions, required actions, completion times, and SRs applicable to their usage and application by adopting changes approved by the staff in TSTF-529. The JAF TS continue to specify the LCOs and specify the remedial measures to be taken if one of these requirements is not satisfied. The TS continue to specify the appropriate SRs to ensure the necessary quality of affected SSCs are maintained. Therefore, the NRC staff finds that the proposed changes to the LCOs and SRs are acceptable because the TS, as amended, will continue to meet 10 CFR 50.36(c)(2) and 50.36(c)(3), respectively.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the New York State official was notified of the proposed issuance of the amendment on September 25, 2024. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves 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 amendment involves no significant hazards consideration, and there has been no public comment on such finding (February 20, 2024; 89 FR 12875). Accordingly, the amendment meets 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 amendment.

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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: M. Hamm Date: October 17, 2024

ML24276A133 NRR-058 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DORL/LPL3/LA NAME JKim KZeleznock (CAdams for)

SLent DATE 10/1/2024 10/4/2024 10/7/2024 OFFICE NRR/DSS/STSB/BC (A)

NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME SMehta HGonzález JKim DATE 9/25/2024 10/17/2024 10/17/2024