ML082831463: Difference between revisions

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Furthermore, LGS, Units 1 and 2 were not required to provide a later response as was requested of 13 selected facilities that were under construction at the time. Review of this issue for LGS was conducted as part of the initial licensing review process.
Furthermore, LGS, Units 1 and 2 were not required to provide a later response as was requested of 13 selected facilities that were under construction at the time. Review of this issue for LGS was conducted as part of the initial licensing review process.
NUREG-0991, "Safety Evaluation Report Related to the Operation of Limerick Generating Station, Units 1 and 2," dated August 1983, section 3.9.5, details the NRC staff's review of this issue for LGS and concludes that reducing the pre-load on the jet pump support beams and continuing inservice inspection activities constitute an acceptable response to the issue. This determination is manifested in the jet pump assembly description contained in the current LGS UFSAR, Section 3.9.5.1.1.8. IE Bulletin 80-07 specified the addition of jet pump surveillances that would provide for early detection of jet pump degradation based on the experience of jet pump failures that occurred at several utilities.
NUREG-0991, "Safety Evaluation Report Related to the Operation of Limerick Generating Station, Units 1 and 2," dated August 1983, section 3.9.5, details the NRC staff's review of this issue for LGS and concludes that reducing the pre-load on the jet pump support beams and continuing inservice inspection activities constitute an acceptable response to the issue. This determination is manifested in the jet pump assembly description contained in the current LGS UFSAR, Section 3.9.5.1.1.8. IE Bulletin 80-07 specified the addition of jet pump surveillances that would provide for early detection of jet pump degradation based on the experience of jet pump failures that occurred at several utilities.
These surveillances were to continue until the cause of the beam failure has been identified and corrected. The bulletin does not prescribe the use of startup test data for baselining the jet pump acceptance criteria. LGS TS Section 4.4.1.2 contains jet pump surveillances that are partially consistent with those specified in IE Bulletin 80-07. However, for LGS, NUREG-0991 does not credit the jet pump surveillances that are the subject of this licensing action for resolution of the jet pump integrity issue. 3.0 TECHNICAL EVALUATION 3.1 Specific Changes Requested The licensee has proposed the following changes to the TS: LGS, Unit 1 -Delete footnote "*To be determined from the startup test program data" from the bottom of TS pages 3/4 4-4 and 3/4 4-4a, and remove the associated asterisk (*) from the word "established" in TS SRs 4.4.1.2.a.1 , 4.4.1.2.a.2, 4.4.1.2.a.3, 4.4.1.2.b.1 , 4.4.1.2.b.2, and 4.4.1.2.b.3. LGS, Unit 2 -Delete footnote "*During the startup test program, data shall be recorded for the parameters listed to provide a basis for establishing specified relationships.
These surveillances were to continue until the cause of the beam failure has been identified and corrected. The bulletin does not prescribe the use of startup test data for baselining the jet pump acceptance criteria. LGS TS Section 4.4.1.2 contains jet pump surveillances that are partially consistent with those specified in IE Bulletin 80-07. However, for LGS, NUREG-0991 does not credit the jet pump surveillances that are the subject of this licensing action for resolution of the jet pump integrity issue. 3.0 TECHNICAL EVALUATION  
 
===3.1 Specific===
Changes Requested The licensee has proposed the following changes to the TS: LGS, Unit 1 -Delete footnote "*To be determined from the startup test program data" from the bottom of TS pages 3/4 4-4 and 3/4 4-4a, and remove the associated asterisk (*) from the word "established" in TS SRs 4.4.1.2.a.1 , 4.4.1.2.a.2, 4.4.1.2.a.3, 4.4.1.2.b.1 , 4.4.1.2.b.2, and 4.4.1.2.b.3. LGS, Unit 2 -Delete footnote "*During the startup test program, data shall be recorded for the parameters listed to provide a basis for establishing specified relationships.
Comparisons of the actual data in accordance with the criteria listed shall commence upon the conclusion of the startup test program" from the bottom of TS pages 3/4 4-4 and 3/4 4-4a, and remove the associated asterisk (*) from the word "established" in TS SRs 4.4.1.2.a.1 , 4.4.1.2.a.2, 4.4.1.2.a.3, 4.4.1.2.b.1 , 4.4.1.2.b.2, and 4.4.1.2.b.3 Evaluation TS SR 4.4.1.2 is designed to detect significant degradation in jet pump performance by daily comparison of recirculation loop flow, total core flow and diffuser-to-Iower plenum differential pressure versus certain established performance criteria. TS Section SR 4.4.1 .2 includes a   
Comparisons of the actual data in accordance with the criteria listed shall commence upon the conclusion of the startup test program" from the bottom of TS pages 3/4 4-4 and 3/4 4-4a, and remove the associated asterisk (*) from the word "established" in TS SRs 4.4.1.2.a.1 , 4.4.1.2.a.2, 4.4.1.2.a.3, 4.4.1.2.b.1 , 4.4.1.2.b.2, and 4.4.1.2.b.3 Evaluation TS SR 4.4.1.2 is designed to detect significant degradation in jet pump performance by daily comparison of recirculation loop flow, total core flow and diffuser-to-Iower plenum differential pressure versus certain established performance criteria. TS Section SR 4.4.1 .2 includes a   
-3 footnote which specifically requires using data recorded during the original plant startup test program for establishing the baseline data. The jet pump failure of concern is a complete mixer displacement due to jet pump beam failure. Jet pump plugging is also of concern since it adds flow resistance to the recirculation loop.
-3 footnote which specifically requires using data recorded during the original plant startup test program for establishing the baseline data. The jet pump failure of concern is a complete mixer displacement due to jet pump beam failure. Jet pump plugging is also of concern since it adds flow resistance to the recirculation loop.
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==4.0 STATE CONSULTATION==
==4.0 STATE CONSULTATION==


In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendment. The State official had no comments.
In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendment. 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. The I'JRC 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.
 
===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. The I'JRC 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 (73 FR 37505). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
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 (73 FR 37505). 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.  
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.  

Revision as of 17:14, 14 October 2018

Limerick, Units 1 and 2 - Issuance of Amendments 196 & 157 Jet Pump Surveillance Changes (TAC Nos. MD7386 and MD7387)
ML082831463
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 11/12/2008
From: Bamford P J
Plant Licensing Branch 1
To: Pardee C G
Exelon Nuclear
Bamford, Peter J., NRR/DORL 415-2833
References
TAC MD7386, TAC MD7387
Download: ML082831463 (18)


Text

UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 November 12, 2008 Mr. Charles G. Pardee President and Chief Nuclear Officer Exelon Nuclear 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 SUB..LIMERICK GENERATING STATION, UNITS 1 AND 2 -

ISSUANCE OF AMENDMENTS RE: JET PUMP SURVEILLANCE CHANGES (TAC NOS. MD7386 AND MD7387)

Dear Mr. Pardee:

The Commission has issued the enclosed Amendment No.196 to Facility Operating License No. NPF-39 and Amendment No.157to Facility Operating License No. NPF-85, for Limerick Generating Station (LGS), Units 1 and 2.

These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated November 13, 2007 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML073170701), as supplemented by letter dated July 29,2008 (ADAMS Accession No. ML082120098).

The amendments consist of removal of footnotes requiring original plant startup data to be used as a baseline for evaluating the performance of the jet pumps during surveillances contained in the TSs. A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Sincerely, Peter Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No.196 to License No. NPF-39
2. Amendment No.157 to License No. I\IPF-85
3. Safety Evaluation cc: Distribution via Listserv UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-352 LIMERICK GENERATING STATION. UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 196 License No. NPF-39 The Nuclear Regulatory Commission (the Commission) has found that: The application for amendment by Exelon Generation Company, LLC (the licensee), dated November 13, 2007, supplemented by letter dated July 29,2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; 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 Commission's regulations; 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 The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied. 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 Facility Operating License No. NPF-39 is hereby amended to read as follows:

-2Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 196, are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance. FOR THE NUCLEAR REGULATORY COMMISSION

?tK Harold K. Chernoff, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance:

November 12, 2008 ATTACHMENT TO LICENSE AMENDMENT NO. 196 FACILITY OPERATING LICENSE NO. NPF-39 DOCKET NO. 50-352 Replace the following page of the Facility Operating License with the revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change. Remove Insert Page 3 Page 3 Replace the following pages 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 3/4 4-4 3/4 4-4 3/44-4a 3/44-4a

-3Pursuant 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; Pursuant to the Act and 10 CFR Parts 30, 40, 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility, and to receive and possess, but not separate, such source, byproduct, and special nuclear materials as contained in the fuel assemblies and fuel channels from the Shoreham Nuclear Power Station. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I (except as exempted from compliance in Section 2.0. below) and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: Maximum Power Level Exelon Generation Company is authorized to operate the facility at reactor core power levels not in excess of 3458 megawatts thermal (100% rated power) in accordance with the conditions specified herein and in Attachment 1 to this license. The items identified in Attachment 1 to this license shall be completed as specified. is hereby incorporated into this license. Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix S, as revised through Amendment NO.196 ,are hereby incorporated into this license.

Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Amendment No. +00, +&+, +47 196 REACTOR COOLANT SYSTEM PUMPS LIMITING CONDITION FOR OPERATION 3.4.1.2 All jet pumps shall be APPLICABILITY:

OPERATIONAL CONDITIONS 1 and With one or more jet pumps inoperable, be in at least HOT SHUTDOWN 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. SlJRVEILLANCE REOUIREMENTS 4.4.1.2 All jet pumps shall be demonstrated OPERABLE as follows: During two recirculation loop operation, each of the above required jet pumps shall be demonstrated OPERABLE prior to THERMAL POWER exceeding 25% of RATED THERMAL POWER and in accordance with the Surveillance Frequency Control Program while greater than 25% of RATED THERMAL POWER by determining recirculation loop flow, total core flow and diffuser-to-lower plenum differential pressure for each jet pump and verifying that no two of the following conditions occur when both recirculation loop indicated flows are in compliance with Specification 3.4.1.3. The indicated recirculation loop flow differs by more than 10% from the established pump speed-loop flow characteristics. The indicated total core flow differs by more than 10% from the established total core flow value derived from recirculation loop flow measurements. The indicated diffuser-to-lower plenum differential pressure of any individual jet pump differs from the established patterns by more than 10%. LIMERICK -UNIT 3/4 4-4 Amendment No. JG, 196 REACTOR COOLANT SYSTEM SURVEILLANCE REOUIREMENTS (Continued) During single recirculation loop operation, each of the above required jet pumps shall be demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program by verifying that no two of the follOWing conditions occur: The indicated recirculation loop flow in the operating loop differs by more than 10% from the established pump speed-loop flow characteristics. The indicated total core flow differs by more than 10% from the established total core flow value derived from single recirculation loop flow measurements. The indicated diffuser-to-lower plenum differential pressure of any individual jet pump differs from established single recirculation loop patterns by more than 10%. The provisions of Specification 4.0.4 are not applicable provided that this surveillance is performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding 25% of RATED THERMAL POWER and upon entering single recirculation loop operation.

LIMERICK -UNIT 1 3/4 4-4a Amendment No. JG, +/-&&, 196 UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 157 License No. NPF-85 The Nuclear Regulatory Commission (the Commission) has found that: The application for amendment by Exelon Generation Company, LLC (the licensee), dated November 13, 2007, supplemented by letter dated July 29,2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; 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 Commission's regulations; 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 The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied. 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 Facility Operating License No. NPF-85 is hereby amended to read as follows:

-2 Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment 1\10.157, are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance.:z,(;;REGULATORY COMMISSION Harold K. Chernoff, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance:

November 12, 2008 ATTACHMENT TO LICENSE AMENDMENT NO.iS? FACILITY OPERATING LICENSE NO. NPF-85 DOCKET NO. 50-353 Replace the following page of the Facility Operating License with the revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change. Remove Insert Page 3 Page 3 Replace the following pages 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 3/4 4-4 3/4 4-4 3/44-4a 3/44-4a

-Pursuant to the Act and 10 CFR Parts 30,40,70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility, and to receive and possess, but not separate, such source, byproduct, and special nuclear materials as contained in the fuel assemblies and fuel channels from the Shoreham Nuclear Power Station. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I (except as exempted from compliance in Section 2.0. below) and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: Maximum Power Level Exelon Generation Company is authorized to operate the facility at reactor core power levels of 3458 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein. Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix S, as revised through Amendment No.1 57 ,are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. Fire Protection (Section 9.5.

SSER-2, -4)* Exelon Generation Company shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report for the facility, and as approved in the NRC Safety Evaluation Report dated August 1983 through Supplement 9, dated August 1989, and Safety Evaluation dated November 20, 1995, subject to the following provision: The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. *The parenthetical notation following the title of license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Amendment No. +, 2+, e+, 68, 1 57 REACTOR COOLANT SYSTEM JET PUMPS LIMITING CONDITION FOR OPERATION 3.4.1.2 All jet pumps shall be APPLICABILITY:

OPERATIONAL CONDITIONS 1 and ACTI With one or more jet pumps inoperable, be in at least HOT SHUTDOWN 12 SURVEILLANCE REOUIREMENTS 4.4.1.2 All jet pumps shall be demonstrated OPERABLE as follows: During two recirculation loop operation, each of the above required jet pumps shall be demonstrated OPERABLE prior to THERMAL POWER exceeding 25% of RATED THERMAL POWER and in accordance with the Surveillance Frequency Control Program while greater than 25% of RATED THERMAL POWER by determining recirculation loop flow, total core flow and diffuser-to-lower plenum differential pressure for each jet pump and verifying that no two of the following conditions occur when both recirculation loop indicated flows are in compliance with Specification 3.4.1.3. The indicated recirculation loop flow differs by more than 10% from the established pump speed-loop flow characteristics. The indicated total core flow differs by more than 10% from the established total core flow value derived from recirculation loop flow measurements. The indicated diffuser-to-lower plenum differential pressure of any individual jet pump differs from the established patterns by more than 10%. LIMERICK -UNIT 3/4 4-4 Amendment No. +4+,157 REACTOR COOLANT SYSTEM SURVEILLANCE REOUIREMENTS (Continued) During single recirculation loop operation, each of the above required jet pumps shall be demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program by verifying that no two of the following conditions occur: The indicated recirculation loop flow in the operating loop differs by more than 10% from the established pump speed-loop flow characteristics. The indicated total core flow differs by more than 10% from the established total core flow value derived from single recirculation loop flow measurements. The indicated diffuser-to-lower plenum differential pressure of any individual jet pump differs from established single recirculation loop patters by more than 10%. The provisions of Specification 4.0.4 are not applicable provided that this surveillance is performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding 25% of RATED THERMAL POWER and upon entering single recirculation loop operation.

LIMERICK -UNIT 3/4 4-4a Amendment No. +4+,157 UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.196 TO FACILITY OPERATING LICENSE NO. NPF-39 AND AMENDMENT NO.157 TO FACILITY OPERATING LICENSE NO. NPF-85 EXELON GENERATION COMPANY, LLC LIMERICK GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353

1.0 INTRODUCTION

By letter dated November 13, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML073170701), as supplemented by letter dated July 29, 2008 (ADAMS Accession No. ML082120098), Exelon Generation Company, LLC (Exelon, the licensee) requested changes to the Technical Specifications (TSs) for Limerick Generating Station (LGS), Units 1 and 2. The changes consist of removal of footnotes requiring original plant startup data to be used as a baseline for evaluating the performance of the jet pumps during surveillances contained in the TSs for LGS, Units 1 and 2. The supplement 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 or Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on July 1,2008 (73 FR 37505). The reason for deleting the footnotes as proposed is that the relationships specified in the TS surveillance requirement (SR) may need to be re-established. For example, fuel assembly or plant configuration changes can change the relative characteristics of recirculation loop flow, jet pump flow and core flow. Hence, requiring the use of startup test flow as the sole basis for the comparisons specified in TS SR 4.4.1.2 may not provide the most accurate benchmark for a comparative flow analysis.

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36 specifies the requirements for what shall be included in TSs. In particular, 10 CFR 50.36(c)(3) specifies that TSs shall include SRs that 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." Additionally, 10 CFR 50.46(b)(5), "Long Term Cooling" requires that "After any calculated initial operation of the emergency core cooling system, the calculated core temperature shall be maintainedatanacceptablylowvalue..." AsdescribedintheLGSUpdatedFinalSafety

-2 Analysis Report (UFSAR), Section 6.3.3.2, one aspect supporting conformance with this criteria is demonstrated generically for General Electric Boiling Water Reactors (BWRs) (and, by inclusion in the UFSAR, for LGS specifically) by keeping the core covered to at least the jet pump suction elevation with the uncovered region cooled by core spray. Since portions of the recirculation piping are located below the assumed two-thirds core height elevation used in the cooling analysis, the integrity of the jet pumps is an important consideration for LGS. Based on the structural failure of a jet pump at Dresden Nuclear Power Station, Unit 3, the NRC issued IE

[Inspection and Enforcement] Bulletin 80-07 on April 14, 1980. As specified in NUREG/CR-3052, "Closeout of IE Bulletin 80-07, BWR Jet Pump Assembly Failure," LGS, Units 1 and 2, were not required to provide a response to the bulletin since they were not operational at the time.

Furthermore, LGS, Units 1 and 2 were not required to provide a later response as was requested of 13 selected facilities that were under construction at the time. Review of this issue for LGS was conducted as part of the initial licensing review process.

NUREG-0991, "Safety Evaluation Report Related to the Operation of Limerick Generating Station, Units 1 and 2," dated August 1983, section 3.9.5, details the NRC staff's review of this issue for LGS and concludes that reducing the pre-load on the jet pump support beams and continuing inservice inspection activities constitute an acceptable response to the issue. This determination is manifested in the jet pump assembly description contained in the current LGS UFSAR, Section 3.9.5.1.1.8. IE Bulletin 80-07 specified the addition of jet pump surveillances that would provide for early detection of jet pump degradation based on the experience of jet pump failures that occurred at several utilities.

These surveillances were to continue until the cause of the beam failure has been identified and corrected. The bulletin does not prescribe the use of startup test data for baselining the jet pump acceptance criteria. LGS TS Section 4.4.1.2 contains jet pump surveillances that are partially consistent with those specified in IE Bulletin 80-07. However, for LGS, NUREG-0991 does not credit the jet pump surveillances that are the subject of this licensing action for resolution of the jet pump integrity issue. 3.0 TECHNICAL EVALUATION

3.1 Specific

Changes Requested The licensee has proposed the following changes to the TS: LGS, Unit 1 -Delete footnote "*To be determined from the startup test program data" from the bottom of TS pages 3/4 4-4 and 3/4 4-4a, and remove the associated asterisk (*) from the word "established" in TS SRs 4.4.1.2.a.1 , 4.4.1.2.a.2, 4.4.1.2.a.3, 4.4.1.2.b.1 , 4.4.1.2.b.2, and 4.4.1.2.b.3. LGS, Unit 2 -Delete footnote "*During the startup test program, data shall be recorded for the parameters listed to provide a basis for establishing specified relationships.

Comparisons of the actual data in accordance with the criteria listed shall commence upon the conclusion of the startup test program" from the bottom of TS pages 3/4 4-4 and 3/4 4-4a, and remove the associated asterisk (*) from the word "established" in TS SRs 4.4.1.2.a.1 , 4.4.1.2.a.2, 4.4.1.2.a.3, 4.4.1.2.b.1 , 4.4.1.2.b.2, and 4.4.1.2.b.3 Evaluation TS SR 4.4.1.2 is designed to detect significant degradation in jet pump performance by daily comparison of recirculation loop flow, total core flow and diffuser-to-Iower plenum differential pressure versus certain established performance criteria. TS Section SR 4.4.1 .2 includes a

-3 footnote which specifically requires using data recorded during the original plant startup test program for establishing the baseline data. The jet pump failure of concern is a complete mixer displacement due to jet pump beam failure. Jet pump plugging is also of concern since it adds flow resistance to the recirculation loop.

Unacceptable deviations from the allowable established baseline data would indicate significant degradation of the affected jet pump. As stated by the licensee, "...over the course of time, various refueling activities, such as fuel assembly replacement or fuel shuffle, as well as physical changes to plant configuration due to modifications to fuel support orifice size or core plate bypass flow etc., can change the recirculation loop flow, jet pump flow, and core flow characteristics. Using startup test program data as the sole basis for comparisons required by TS SR 4.4.1.2.a and 4.4.1.2.b may not provide an accurate indication of the current performance characteristics of the jet pumps." As such, the licensee proposes to delete the footnote that requires using only the startup test data. The licensee stated that "Deleting the footnote allows the plant the flexibility to re-establish recirculation loop flow, jet pump flow, and core flow characteristics if there have been any plant changes that may impact these characteristics." As proposed by the licensee, the up-to-date "data collected will be plotted against the existing acceptance criteria (curves) specified in the daily jet pump operability surveillance tests. A determination will be made whether or not to change the existing acceptance criteria. If necessary, the acceptance criteria in the daily jet pump operability surveillance tests will be revised based on the data collected to establish new baseline acceptance criteria. If no change is necessary, the existing daily jet pump surveillance tests will remain unchanged." The licensee stated that changes to the acceptance criteria (re-baseline) will be made consistent with the rationale contained in General Electric (GE) Services Information Letter (SIL)-330, "Jet Pump Beam Cracks," dated June 9, 1980. This document was evaluated by the NRC during the close out review of IE Bulletin 80-07 in NUREG/CR-3052.

The NUREG/CR-3052 review does not specifically address re-baseline criteria, though it does endorse the surveillance criteria listed in the GE SIL, which do not contain the footnote requiring the use of startup data. The use of appropriate re-baseline criteria maintains the surveillance intent and thus continues to support compliance with 10 CFR 50.36. By continuing to support the periodic assessment of jet pump integrity as was originally intended, the removal of the footnotes also supports compliance with 10 CFR 50.46. Since the footnotes proposed for deletion are unique to LGS among the BW R/4 plants in the United States, the basis for their inclusion into the LGS TS was reviewed by the NRC staff. The Low Pressure Coolant Injection lines do not inject through the jet pumps at LGS; they inject directly into the core shroud through separate nozzles. While this feature is somewhat unique to LGS, it does not relate to the method of establishing jet pump surveillance acceptance criteria.

The NRC staff therefore concludes that the design and operation of the jet pumps at LGS do not contain any unique characteristics that would specifically require the use of startup test data for the re-baseline acceptance criteria.

In accordance with the provisions of LGS UFSAR 3.9.5.1.1.8, LGS performs inspections specifically designed to look at jet pump integrity. These inspections are done in accordance with BWRVIP [BWR Vessels and Internals Project]-41 and BWRVIP-48-A as a means of accomplishing the industry experience based inspection requirements described in NUREG-0991 and the LGS UFSAR. BWRVIP-41 was approved by the NRC staff in a safety evaluation dated February 4,2001 (ADAMS Accession No. ML010460111) and BWRVIP-48-A was approved by the NRC staff in a letter dated July 25, 2005 (ADAMS Accession No.

ML052130284). Periodic jet pump inspections, along with the reduced beam preload, have been judged by the NRC staff to be an acceptable response to the jet pump integrity issue detailed in IE Bulletin 80-07 at LGS and are unchanged by this licensing action. Though not

-4relied upon for making this regulatory determination, the I'JRC staff notes that the proposed changes are consistent with NUREG-1433, Revision 3, "Standard Technical Specifications, General Electric Plants, BWR/4." The proposed TS changes reflect the use of more up-to-date data for performing the jet pump surveillance, which, in turn, will help ensure that jet pump degradation is identified early before jet pump failure occurs. The NRC staff finds that the proposed TS maintain appropriate surveillances for the jet pumps as required by 10 CFR 50.36 and by continuing to ensure jet pump integrity, support compliance with 10 CFR 50.46. On the basis that the proposed TS changes will use more accurate and appropriate data for performing the jet pump surveillance, as well as the previously accomplished reduced beam pre-load and continuance of the inspection requirements described in LGS UFSAR 3.9.5.1.1.8 to detect jet pump hold down beam integrity, the NRC staff concludes that the proposed TS amendment is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendment. 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. The I'JRC 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 (73 FR 37505). 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) such activities will be conducted in compliance with the Commission's 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 Y.S. Huang Peter Bamford Date: November 12,2008 November 12, 2008 Mr. Charles G. Pardee President and Chief Nuclear Officer Exelon Nuclear 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 LIMERICK GENERATING STATION, UNITS 1 AND 2 -ISSUANCE OF AMENDMENTS RE: JET PUMP SURVEILLANCE CHANGES (TAC NOS.

MD7386 AND MD7387)

Dear Mr. Pardee:

The Commission has issued the enclosed Amendment No. 196 to Facility Operating License No. NPF-39 and Amendment No. 157 to Facility Operating License No. NPF-85, for Limerick Generating Station (LGS), Units 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated November 13, 2007 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML073170701), as supplemented by letter dated July 29, 2008 (ADAMS Accession No. ML082120098).

The amendments consist of removal of footnotes requiring original plant startup data to be used as a baseline for evaluating the performance of the jet pumps during surveillances contained in the TSs. A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Sincerely, /raJ Peter Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 196 to License No. NPF-39
2. Amendment No. 157 to License No. NPF-85
3. Safety Evaluation cc: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDorlLpl1-2 Resource RidsNrrPMPBamford Resource RidsNrrLAABaxter Resource GHill,OIS (2) RidsNrrDorlDpr Resource RidsRgn 1 MailCenter Resource RidsAcrsAcnw_MailCTR Resource LPL 1-2 R/F RidsOgcRp Resource RidsNrrDciCptb Resource YHuang, NRR RidsNrrDirsltsb Resource *.ML08283 3 via correspon d ence A mendment Accession Number: 146 ;

LPLI-2/PM LPLI-2/LA CPTB/BC ITSB/BC OGC LPLI-2/BC Name PBamford ABaxter JMcHaie

  • RElliolt JBielecki (NLO w/comments)

HChernoff Date 10/20/08 10/21/08 OS/29/2008 10/27/08 10/30/08 11/12/08 ..Official Record Copy