ML24204A071

Issuance of Amendment Nos. 263 and 225 Technical Specifications for Main Steam Line Tunnel Temperature

ML24204A071
Person / Time
Site:	Limerick
Issue date:	07/29/2024
From:	Audrey Klett Plant Licensing Branch 1
To:	Rhoades D Constellation Energy Generation
Klett, AL
References
EPID L-2024-LLA-0079
Download: ML24204A071 (1)

Text

July 29, 2024

Mr. David P. Rhoades Senior Vice President President and Chief Nuclear Officer Constellation Energy Generation, LLC 4300 Winfield Rd.

Warrenville, IL 60555

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 ISSUANCE OF AMENDMENT NOS. 263 AND 225 RE: TECHNICAL SPECIFICATIONS FOR MAIN STEAM LINE TUNNEL TEMPERATURE (EPID L-2024-LLA-0079)

Dear David Rhoades:

The U.S. Nuclear Regulatory Commission (NRC or the Commission) has issued the enclosed Amendment Nos. 263 and 225 to Renewed Facility Operating License Nos. NPF-39 and NPF-85 for the Limerick Generating Station, Units 1 and 2 (Limerick), respectively. The amendments consist of changes to the technical spec ifications (TS) in response to Constellation Energy Generation, LLCs application dated June 13, 2024 (Agencywide Documents Access and Management System Accession No. ML24 165A264), as supplemented by letter dated July 19, 2024 (ML24201A166).

The enclosed amendments revise Limericks TS by replacing automatic main steam isolation valve isolation requirements with a monitoring requirement and a manual shutdown if the turbine enclosure main steam line tunnel temperature exceeds a certain value and main steam line pressure boundary leakage is detected. Specifically, the automatic main steam isolation valve isolation requirements would be removed via deletion of Function 1.g, Turbine Enclosure - Main Steam Line Tunnel Temperature - High, from TS Table 3.3.2-1, Isolation Actuation Instrumentation, Table 3.3.2-2, Isolation Actuation Instrumentation Setpoints, Table 3.3.2-3, Isolation System Instrumentation Response Time, and Table 4.3.2.1-1, Isolation Actuation Instrumentation Surveillance Requirements. In li eu of automatic main steam isolation valve isolation, the amendments add new TS 3/4.7.9, Turbine Enclosure Main Steam Line Tunnel Temperature, which, if turbine enclosure main steam line tunnel maximum temperature exceeds a certain value, requires immediate action to verify there is no main steam line pressure boundary leakage or, otherwise, take shutdown actions.

D. Rhoades

A copy of the related safety evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Audrey Klett, Senior Project Manager Plant Licensing Branch 1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 263 to NPF-39

2. Amendment No. 225 to NPF-85

3. Safety Evaluation

cc: Listserv

CONSTELLATION ENERGY GENERATION, LLC

DOCKET NO. 50-352

LIMERICK GENERATING STATION, UNIT 1

AMENDMENT TO RENEWED FACI LITY OPERATING LICENSE

Amendment No. 263 Renewed License No. NPF-39

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

A. The application for amendment by Constellation Energy Generation, LLC, dated June 13, 2024, as supplemented by letter dated July 19, 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.

Enclosure 1

2. Accordingly, the license is amended by changes to the renewed facility operating license and technical specifications, as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-39 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 No. 263, are hereby incorporated into this renewed license. Constellation Energy Generation, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented immediately.

FOR THE NUCLEAR REGULATORY COMMISSION

Hipólito González, Chief Plant Licensing Branch 1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-39 and Technical Specifications

Date of Issuance: July 29, 2024

ATTACHMENT TO LICENSE AMENDMENT NO. 263

LIMERICK GENERATING STATION, UNIT 1

RENEWED FACILITY OPERATING LICENSE NO. NPF-39

DOCKET NO. 50-352

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 a marginal line indicating the area of change.

Remove Insert 3 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 Insert 3/4 3-11 3/4 3-11 3/4 3-18 3/4 3-18 3/4 3-23 3/4 3-23 3/4 3-27 3/4 3-27

---

3/4 7-34

(2) Pursuant to the Act and 10 CFR Part 70, to receive, possess and to use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended;

(3) 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) 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

(5) 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.

C. This renewed 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.D. 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:

(1) Maximum Power Level

Constellation Energy Generation, LLC is authorized to operate the facility at reactor core power levels not in excess of 3515 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 renewed license shall be completed as specified. Attachment 1 is hereby incorporated into this renewed license.

(2) Technical Specifications

The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 263, are hereby incorporated into this renewed license. Constellation Energy Generation, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Renewed License No. NPF-39 Amendment No. 263 TRIP FUNCTION

1. MAIN STEAM LINE ISOLATION

a. Reactor Vessel Water Level 1)Low, Low-Level 2 2)Low, Low, Low-Level 1

b. DELETED C. Main Steam Line Pressure -Low

d. Main Steam Line Flow -High

e. Condenser Vacuum -Low

f. Outboard MSIV Room Temperature -High

g. DELETED

h. Manual Initiation

2. RHR SYSTEM SHUTDOWN COOLING MODE

a. Reactor Vessel Water Level Low -Level 3

b. Reactor Vessel ( RHR Cut-In Permissive) Pressure -High C. Manual Initiation LIMERICK -UN IT 1 TABLE 3.3.2-1 ISOLATION ACTUATION INSTRUMENTATION ISOLATION SIGNAL (a)

B C

DELETED p

E Q

F( f)

DELETED NA ISOLATION A

V NA 3/4 3-11 MINIMUM OPERABLE CHANNELS PER TRIP SYSTEM (b) 2 2

DELETED 2

2/line 2

2 DELETED 2

2 2

1 APPLICABLE OPERATIONAL CONDITION 1, 2, 3 1, 2, 3 DELETED 1

1, 2, 3 1, 2**. 3**

1, 2, 3 DELETED 1, 2, 3 1, 2. 3 1, 2.3 1, 2.3 Amendment No. 8-, ACTION 21 21 DELETED 22 20 21 21 DELETED 24 23 23 24 9-

• 5

• 263 TABLE 3.3.2-2 ISOLATION ACTUATION INSTRUMENTATION SETPOINTS TRIP FUNCTION TRIP SETPOINT ALLOWABLE VALUE

1. MAIN STEAM LINE ISOLATION

a. Reactor Vessel Water Level

1) Low, Low - Level 2 ~ - 38 inches* ~ - 45 inches

2) Low, Low, Low - Level 1 ~ - 129 inches* ~ - 136 inches

b. DELETED DELETED DELETED

c. Main Steam Line Pressure - Low ~ 840 psig ~ 821 psig

d. Main Steam Line Flow - High ~ 122.1 psid ~ 123 psid

e. Condenser Vacuum - Low 10.5 psia ~10.1 psia/~ 10.9 psia

f. Outboard MSIV Room Temperature - High ~ 192°F ~ 200°F

g. DELETED DELETED DELETED

h. Manual Initiation N.A. N.A.

2. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a. Reactor Vessel Water Level Low - Level 3 ~ 12.5 inches* ~ 11.0 inches

b. Reactor Vessel (RHR Cut-in Permissive) Pressure - High ~ 75 psig ~ 95 psig

c. Manual Initiation N.A. N.A.

LIMERICK - UNIT 1 3/4 3-18 Amendment No. 8, &9-, -+/--8-6, 2-2-, 263 TABLE 3.3.2-3 ISOLATION SYSTEM INSTRUMENTATION RESPONSE TIME TRIP FUNCTION RESPONSE TIME (Seconds)#

1. MAIN STEAM LINE ISOLATION

a. Reactor Vessel Water Level

1) Low, Low - Level 2 N.A.

2) Low, Low, Low - Level 1 D. Otftftf*

b. DELETED DELETED

c. Main Steam Line Pressure - Low D.0###*

d. Main Steam Line D.0###*

Flow - High

e. Condenser Vacuum - Low N.A.

f. Outboard MSIV Room Temperature - High N.A.

g. DELETED DELETED

h. Manual Initiation N.A.

2. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a. Reactor Vessel Water Level Low - Level 3 N.A.

b. Reactor Vessel ( RHR Cut-In Permissive) Pressure - High N.A.

c. Manual Initiation N.A.

3. REACTOR WATER CLEANUP SYSTEM ISOLATION

a. RWCS ~ Flow - High N.A.#if

b. RWCS Area Temperature - High N.A.

c. RWCS Area Ventilation

~Temperature - High N.A.

d. SLCS Initiation N.A.

e. Reactor Vessel Water Level -Low, Low - Level 2 N.A.

f. Manual Initiation N.A.

LIMERICK - UNIT 1 3/4 3-23 Amendment No. 9-,8-9.~. 1-4, 263 TABLE 4.3.2.1-1 ISOLATION ACTUATION INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL FUNCTIONAL CHANNEL CHANNEL CONDITIONS FOR WHICH OPERATIONAL TRIP FUNCTION CHECK( a) TEST( a) CALIBRATION(a) SURVEILLANCE REQUIRED

1. MAIN STEAM LINE ISOLATION

a. Reactor Vessel Water Level

1) Low, Low, Level 2 1, 2' 3

2) Low, Low, Low - Level 1 1, 2' 3

b. DELETED DELETED

c. Main Steam Line Pressure - Low 1

d. Main Steam Line Flow - High 1, 2' 3

e. Condenser Vacuum - Low 1, 2**, 3**

f. Outboard MSIV Room Temperature - High 1, 2' 3

g. DELETED DELETED

h. Manual Initiation N.A. N.A. 1. 2' 3

2. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a. Reactor Vessel Water Level4#f Low - Level 3 1, 2' 3

b. Reactor Vessel ( RHR Cut-In 1, 2' 3 Permissive) Pressure - High

c. Manual Initiation N.A. N.A. 1, 2' 3

LIMERICK - UNIT 1 3/4 3-27 Amendment No. 8-, 3-, 9-, 8-9-, +86, 263 PLANT SYSTEMS 3/4.7.9 TURBINE ENCLOSURE MAIN STEAM LINE TUNNEL TEMPERATURE LIMITING CONDITION FOR OPERATION 3.7.9 The Turbine Enclosure Main Steam Line Tunnel temperature shall be 175 ° F.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, AND 3 ACTION:

With the Turbine Enclosure (TE) Main Steam Line Tunnel Temperature> 175 ° F, immediately and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter verify there is no leakage from the Main Steam Line pressure boundary within the TE Main Steam Line Tunnel. Otherwise, be in HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENT 4.7.9.1 The Turbine Enclosure Main Steam Line Tunnel temperature shall be determined to be 175 ° F in accordance with the Surveillance Frequency Control Program.

LIMERICK -UNIT 1 3/4 7-34 Amendment No. 263 CONSTELLATION ENERGY GENERATION, LLC

DOCKET NO. 50-353

LIMERICK GENERATING STATION, UNIT 2

AMENDMENT TO RENEWED FACI LITY OPERATING LICENSE

Amendment No. 225 Renewed License No. NPF-85

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

A. The application for amendment by Constellation Energy Generation, LLC, dated June 13, 2024, as supplemented by letter dated July 19, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations as 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.

Enclosure 2

2. Accordingly, the license is amended by changes to the renewed facility operating license and technical specifications, as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed 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 No. 225, are hereby incorporated into this renewed license. Constellation Energy Generation, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented immediately.

FOR THE NUCLEAR REGULATORY COMMISSION

Hipólito González, Chief Plant Licensing Branch 1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-85 and Technical Specifications

Date of Issuance: July 29, 2024

Enclosure 2 ATTACHMENT TO LICENSE AMENDMENT NO. 225

LIMERICK GENERATING STATION, UNIT 2

RENEWED FACILITY OPERATING LICENSE NO. NPF-85

DOCKET NO. 50-353

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 a marginal line indicating the area of change.

Remove Insert 3 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 Insert 3/4 3-11 3/4 3-11 3/4 3-18 3/4 3-18 3/4 3-23 3/4 3-23 3/4 3-27 3/4 3-27

---

3/4 7-34

(2) Pursuant to the Act and 10 CFR Part 70, to receive, possess and to use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended;

(3) 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) 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

(5) 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.

C. This renewed 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.D. 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:

(1) Maximum Power Level

Constellation Energy Generation, LLC is authorized to operate the facility at reactor core power levels of 3515 megawatts thermal (100 percent rated

power) in accordance with the conditions specified herein.

(2) Technical Specifications

The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised

through Amendment No. 225, are hereby incorporated into this renewed license. Constellation Energy Generation, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Renewed License No. NPF-85 Amendment No. 22 5 2 ) N    N

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N
 25 TABLE 3.3.2-2 ISOLATION ACTUATION INSTRUMENTATION SETPOINTS TRIP FUNCTION TRIP SETPOINT ALLOWABLE VALUE

1. MAIN STEAM LINE ISOLATION

a. Reactor Vessel Water Level

1) Low, Low - Level 2 2_ - 38 inches* 2_ - 45 inches

2) Low, Low, Low - Level 1 2_ - 129 inches* 2_ - 136 inches

b. DELETED DELETED DELETED

c. Main Pressure - Low Steam Line 2_ 840 psig 2_ 821 psig

d. Main Flow - High Steam Line S. 122.1 psid S. 123 psid

e. Condenser Vacuum Low 10.5 psia 2_10.1 psia/~ 10.9 psia

f. Outboard Temperature - High MSIV Room S. 192°F S 200°F

g. DELETED DELETED DELETED

h. Manual Initiation N. A. N.A.

2. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a. Reactor Vessel Water Level Low - Level 3 2_ 12.5 inches* 2_ 11.0 inches

b. Reactor Vessel (RHR Permissive) Pressure - High Cut-in S. 75 psig S. 95 psig

c. Manual Initiation N.A. N.A.

LIMERICK - UNIT 2 3/4 3-18 Amendment No. +/--, ~. -+/--83-,

225 TABLE 3.3.2-3 ISOLATION SYSTEM INSTRUMENTATION RESPONSE TIME TRIP FUNCTION RESPONSE TIME (Seconds)#

1. MAIN STEAM LINE ISOLATION

a. Reactor Vessel Water Level

1) Low, Low - Level 2 N.A.

2) Low, Low, Low - Level 1 D.Oif##*

b. DELETED DELETED

c. Main Steam Line Pressure - Low D.Oif##*

d. Main Steam Line Flow - High D.Oif##*

e. Condenser Vacuum - Low N.A.

f. Outboard MSIV Room Temperature - High N.A.

g. DELETED DELETED

h. Manual Initiation N.A.

2. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a. Reactor Vessel Water Level Low - Level 3 N.A.

b. Reactor Vessel C RHR Cut-In Permissive) Pressure - High N.A.

c. Manual Initiation N.A.

3. REACTOR WATER CLEANUP SYSTEM ISOLATION

a. RWCS ~ Flow - High N. A. if#

b. RWCS Area Temperature - High N.A.

c. RWCS Area Ventilation

~Temperature - High N.A.

d. SLCS Initiation N.A.

e. Reactor Vessel Water Level -Low, Low - Level 2 N.A.

f. Manual Initiation N.A.

LIMERICK - UNIT 2 3/4 3-23 Amendment No. 2-,-93-, -+/--7-5-,

225 TABLE 4.3.2.1-1 ISOLATION ACTUATION INSTRUMENTATION SURVEILLANCE REQUIREMENTS TRIP FUNCTION

1. MAIN STEAM LINE ISOLATION

a. Reactor Vessel Water Level

1) Low, Low, Level 2

2) Low, Low, Low -Level

b. DELETED C. Main Steam Line Pressure -Low

d. Main Steam Line Flow -High

e. Condenser Vacuum -Low

f. Outboard MSIV Room Temperature -High

g. DELETED

h. Manual Initiation1

2. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a.

b.

C. Reactor Vessel Water Level4#f Low -Level 3 Reactor Vessel ( RHR Cut-In Permissive) Pressure -High Manual Initiation LIMERICK -UNIT 2 CHANNEL CHECK (a)

N.A.

N.A.

3/4 3-27 CHANNEL FUNCTIONAL TEST (a) OPERATIONAL CHANNEL CONDITIONS FOR WHICH CALIBRATION(a) SURVEILLANCE REQUIRED 1, 2, 3 1, 2, 3 DELETED 1

1, 2, 3 1, 2** ' 3**

1, 2, 3 DELETED N.A. 1.2, 3 1, 2, 3 1, 2, 3 N.A. 1, 2, 3 Amendment No. H, 2-,. +/--4-7-,

225 PLANT SYSTEMS 3/4.7.9 TURBINE ENCLOSURE MAIN STEAM LINE TUNNEL TEMPERATURE LIMITING CONDITION FOR OPERATION 3.7.9 The Turbine Enclosure Main Steam Line Tunnel temperature shall be 175 ° F.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, AND 3 ACTION:

With the Turbine Enclosure (TE) Main Steam Line Tunnel Temperature> 175 ° F, immediately and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter verify there is no leakage from the Main Steam Line pressure boundary within the TE Main Steam Line Tunnel. Otherwise, be in HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENT 4.7.9.1 The Turbine Enclosure Main Steam Line Tunnel temperature shall be determined to be 17 5° F in accordance with the Surveillance Frequency Control Program.

LIMERICK -UNIT 2 3/4 7-34 Amendment No. 225 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR

AMENDMENT NO. 263 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-39

AMENDMENT NO. 225 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-85

CONSTELLATION ENERGY GENERATION, LLC

LIMERICK GENERATING STATION, UNITS 1 AND 2

DOCKET NOS. 50-352 AND 50-353

1.0 INTRODUCTION

By letter dated June 13, 2024 (Agencywide Documents Access and Management System Accession No. ML24165A264), as supplemented by letter dated July 19, 2024 (ML24201A166),

Constellation Energy Generation, LLC (the licensee) requested amendments to Renewed Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (Limerick),

Units 1 and 2, respectively. The licensee proposed to revise Limericks technical specifications (TS) by replacing automatic main steam isolation valve (MSIV) isolation requirements with a monitoring requirement if the turbine enclosure (TE) main steam line (MSL) tunnel temperature exceeds a certain value and a manual shutdown if MSL pressure boundary leakage is detected. The supplement dated July 19, 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 (NSHC) determination as published in the Federal Register (FR) on June 25, 2024 (89 FR 53124).

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36(c)(2) requires that technical specifications include limiting conditions for operation (LCOs). Per 10 CFR 50.36(c)(2)(i), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation also requires that when an LCO 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.

Section 50.36(c)(3) of 10 CFR requires that technical specifications include items in the category of surveillance requirements (SRs), which 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 LCOs will be met.

Enclosure 3

Section 20.1301, Dose limits for individual members of the public, of 10 CFR requires, in part, that licensees shall conduct operations so that the total effective dose equivalent to individual members of the public from the licensed operation does not exceed 0.1 roentgen equivalent man (rem) (1 millisievert) in a year, exclusive of the dose contributions from background radiation.

General design criterion (GDC) 30, Quality of reactor coolant pressure boundary, of Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50 states, Components which are part of the reactor coolant pressure boundary shall be designed, fabricated, erected, and tested to the highest quality standards practical. Means shall be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant leakage.

GDC 54, Piping systems penetrating containment, of Appendix A to 10 CFR Part 50 states, in part, Piping systems penetrating primary reactor containment shall be provided with leak detection, isolation, and containment capabilities having redundancy, reliability, and performance capabilities which reflect the importance to safety of isolating these piping systems.

NRC Regulatory Guide 1.174, Revision 3, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis (ML17317A256), provides general guidance concerning analysis of the risk associated with proposed changes in plant design and operation.

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes

The proposed change would remove Function 1.g, Turbine Enclosure - Main Steam Line Tunnel Temperature - High, and inserts the word Deleted in TS tables 3.3.2-1, Isolation Actuation Instrumentation, 3.3.2-2, Isolation Actuation Instrumentation Setpoints, 3.3.2-3, Isolation System Instrumentation Response Time, and 4.3.2.1-1, Isolation Actuation Instrumentation Surveillance Requirements. The licensee stated that the deletion of Function 1.g does not require modification to any Actions or SRs.

The proposed change would also add a new TS 3/4.7.9, Turbine Enclosure Main Steam Line Tunnel Temperature. The licensee stated that the new LCO 3.7.9 would require the TE MSL tunnel maximum temperature to be less than or equal to () 175 degrees Fahrenheit (°F) and that the specification is applicable in Operational Conditions 1, 2, and 3, the same as existing Function 1.g. SR 4.7.9.1 requires verification that the TE MSL tunnel temperature is 175 °F on a frequency controlled by the Surveillance Frequency Control Program (SFCP). The initial frequency would be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

In section 1 of attachment 1 to its license amendment request (LAR), the licensee stated:

In the proposed TS, if the TE MSL tunnel maximum temperature exceeds 175°F, the Action requires immediate action to verify that no MSL leak exists, and periodic verification every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. If it cannot be verified that there is no MSL pressure boundary leakage or if the periodic verification is not performed, a plant shutdown is required. The plant must be in Operational

Condition 3 (Hot Shutdown) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Operational Condition 4 (Cold Shutdown) within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3.2 System Description

In section 3 of attachment 1 to its LAR, the licensee provided the following system description:

The TE MSL Tunnel is defined as the area in which the four-safety related main steam lines are routed in the non-safety related main condenser compartment.

The steam lines, after entering the TE from the outboard MSIV room, run the length and half the turbine enclosure width until they enter the main turbine stop valves. The steam line arrangement in this plant area is shown in UFSAR

[Updated Final Safety Analysis Report] Figure 3.6-5.

The TE MSL Tunnel steam leak detection thermocouples are located approximately three feet above the main steam lines. There are thirty-two separate thermocouple locations arranged in eight groups of four sensors that monitor the entire length of the four main steam lines up to the turbine stop valve inlets in this large plant area. The purpose of the steam leak detection thermocouple is to monitor and detect a passive piping pressure boundary leak (not packing, gasket, or other non-pressure boundary leakage) prior to the turbine stop valves.

The purpose of the TE MSL Tunnel Temperature isolation function is to provide timely detection and isolation of small high energy Main Steam line leaks prior to catastrophic failure of the piping while maintaining sufficient margin above normal operating temperatures to avoid spurious isolation. The TE MSL Tunnel Temperature instrumentation is part of the MSIV Group 1 isolation logic and isolates the normally open MSIVs and the normally closed Main Steam line drain valves.

3.3 Evaluation of Main Stem Line Isolation

The leak-before-break (LBB) concept is based on analysis that demonstrates, by deterministic fracture mechanics, that a crack would grow through the wall, resulting in a leak, and that this postulated small through wall flaw in plant-specific piping would be detected by the plants leakage monitoring systems long before the flaw could grow to unstable size. Leakage exceeding the limit specified requires operator action or plant shutdown.

The licensee stated in section 3 of attachment 1 to its LAR:

The purpose of this preemptive feature is to detect a steam line leak prior to the flow rate corresponding to a critical crack size which will not propagate into a full pipe rupture for the respective system piping. For Limerick the critical crack length for main steam piping, as depicted in UFSAR Figure 5.2-12, is approximately 300 gpm [gallons per minute]. The corresponding 25 gpm summer and 35 gpm winter threshold is adequate to assure early detection and manual isolation, after condition confirmation, of a main steam line leak within the Turbine Enclosure with a large amount of margin to the critical crack size. This automatic leak before break detection isolation function is not required to satisfy any design basis event.

As listed in the four affected TS tables, the following functions will continue to provide MSL isolation:

1.a. Reactor Vessel Water level - Low, Low, Low - Level 1, 1.c. Main Steam Line Pressure - Low, 1.d. Main Steam Line Flow - High, 1.e. Condenser Vacuum - Low, and 1.f. Outboard MSIV Room Temperature - High.

The NRC staff finds the deletion of Function 1.g fr om the various TS tables acceptable because the original purpose of isolating the MSL would continue to be maintained by other TS provisions and because early detection that can be completed by the licensee provides margin to the critical crack size being reached. The proposed TS 3.7.9 would require a plant shutdown if a leak is detected, and Functions 1.a and 1.c through 1.f, which are not being revised by this LAR, would continue to provide MSL isolation. Therefore, the NRC staff finds that the proposed change to delete Function 1.g from the various TS tables is acceptable and that Limerick, Units 1 and 2, would continue to meet GDCs 30 and 54.

3.4 Evaluation of Dose Limits

In section 3 of attachment 1 to its LAR, the licensee stated:

The TE MSL Tunnel Temperature instrumentation and logic is not required to mitigate any design basis event and credit for this isolation instrumentation is not taken in any transient or accident analysis in UFSAR Chapter 15. Bounding analyses are performed for large breaks, such as Main Steam line breaks that solely credit the automatic Main Steam line high flow isolation. The TE MSL Tunnel Temperature isolation and reactor vessel low level and low steam pressure isolations provide a diverse isolation function to the credited Main Steam line high flow isolation. This function does not require an automatic isolation of the MSLs on TE MSL tunnel high temperature in order to assure plant safety. Given the purpose of the function, the consequences of an automatic reactor scram due to closure of the MSIVs is unwarranted.

The Applicability of LCO 3.7.9 is Operational Conditions 1, 2, and 3. In Operational Conditions 1, 2, and 3, a Design Basis Accident (DBA) could result in the release of radioactive material into the TE MSL Tunnel if there is a leak in the MSLs. In Operational Conditions 4 and 5, the probability and consequences of a DBA with fission product release into the TE MSL Tunnel are reduced because of the pressure and temperature limitations in these conditions.

If the elevated temperature is determined to not be due to a MSL pressure boundary leak and as long as the TE MSL tunnel temperature exceeds 175 °F, the Actions require verification every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that no MSL pressure boundary leak exists. The area monitored in the TE MSL Tunnel has elevated radiation levels and adverse environmental conditions. The 12-hour Completion Time balances the small likelihood of a MSL pressure boundary leak occurring since the last verification against the risks of exposing workers to the radiological and environmental conditions in order to perform the verification.

In accordance with 10 CFR 20.1301, the licensee is required, in part, to conduct operations so that the total effective dose equivalent to individual members of the public from the licensed operation does not exceed 0.1 rem in a year. As described in the proposed TS 3.7.9, the licensee would monitor the Limerick TE MSL tunnel for MSL leakage and take actions to correct the condition if a small MSL leak is detected. The proposed TS 3.7.9 would preserve the initial conditions assumed in the DBA and transient an alyses. Therefore, the NRC staff finds that the proposed change to delete Function 1.g from the various TS tables will not challenge the dose limits established in 10 CFR 20.1301.

3.5 Evaluation of Proposed TS Changes

In section 3 of attachment 1 to its LAR, the licensee stated:

The Applicability of LCO 3.7.9 is Operational Conditions 1, 2, and 3. In Operational Conditions 1, 2, and 3, a Design Basis Accident (DBA) could result in the release of radioactive material into the TE MSL Tunnel if there is a leak in the MSLs. In Operational Conditions 4 and 5, the probability and consequences of a DBA with fission product release into the TE MSL Tunnel are reduced because of the pressure and temperature limitations in these conditions.

Therefore, maintaining TE MSL tunnel temperature within limits is not required in Operational Conditions 4 or 5. The proposed Applicability is the same as the current Function 1.g.

The proposed Surveillance Requirement (SR) 4.7.9.1 requires verification that the TE MSL tunnel temperature is 175°F. The Frequency is controlled under the SFCP, and the initial frequency will be every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. As stated in SR 3.0.1, SRs must be met between performances of the Surveillance. If the TE MSL tunnel maximum temperature exceeds 175°F, operators will be alerted to take action.

The TS 3.7.9 Actions apply if the TE MSL tunnel temperature is exceeded. It requires immediate action to determine if there is an MSL pressure boundary leak.

If the elevated temperature is determined to not be due to a MSL pressure boundary leak and as long as the TE MSL tunnel temperature exceeds 175°F, the Actions require verification every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that no MSL pressure boundary leak exists. The area monitored in the TE MSL Tunnel has elevated radiation levels and adverse environmental conditions. The 12-hour Completion Time balances the small likelihood of a MSL pressure boundary leak occurring since the last verification against the risks of exposing workers to the radiological and environmental conditions in order to perform the verification.

If a MSL pressure boundary leak is detected or if the periodic verification is not performed, the actions require a plant shutdown. The plant must be brought to least Operational Condition 3 (Hot Shutdown) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Operational Condition 4 (Cold Shutdown) within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The proposed times are consistent with the requirements of similar specifications and are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

As evaluated in section 3.3 of this safety evaluation, the proposed change replaces an automatic MSL isolation on high TE MSL tunnel temperature with a monitoring and evaluation requirement and a manual reactor shutdown if MSL leakage exists. The NRC staff found this change acceptable because Function 1.g, as identif ied by the licensee, would continue to be maintained by other TS provisions for isolating the MSL. Early detection that can be completed by the licensee also provides margin to the critical crack size being reached. The proposed TS 3.7.9 would require a plant shutdown if a leak is detected, and other Functions 1.a and 1.c through 1.f would continue to provide automatic MSL isolation.

The current TE MSL tunnel maximum temperature is < 175 °F and is not being changed. The newly proposed LCO 3.7.9 and SR 4.7.9.1 requires verification that the current TE MSL tunnel maximum temperature is < 175 °F on a frequency controlled by the SFCP and continues to be applicable in Operational Conditions 1, 2, and 3, which is the same as the existing Function 1.g.

If the TE MSL tunnel temperature exceeds 175 °F, then actions would require the immediate verification that no MSL leak exists and would also require the licensee to verify no MSL leak every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. The NRC staff review found that the area temperature monitoring would detect MSL leakage. If a large MSL break occurred, then the MSIVs would automatically close based on a MSL Flow - High signal. The NRC finds the 12-hour completion time reasonable based on operating experience and the likelihood of a MSL leak. If it cannot be verified that there is not an MSL leak or if the periodic verification is not performed, then TS 3.7.9 actions would require the plant to be in Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Cold Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The NRC staff reviewed the proposed TS changes and finds that TS 3.7.9 meets the requirements of 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3) because the proposed TS would require a plant shutdown if a leak were detected and other Functions 1.a and 1.c through 1.f would continue to provide MSL isolation. Based on the above, the NRC staff finds the proposed change acceptable.

3.6 Risk Insights

The NRC staff performed a conservative assessment of the impact of the proposed elimination of the automatic isolation function from a high TE MSL tunnel temperature. The staff concludes that the available risk insights provided in section 3 of the LAR related to the proposed elimination of an automatic isolation function are acceptable for the purposes of supporting the deterministic evaluation. Specifically, the independent risk assessment performed by the NRC staff using the Limerick Generating Station, Units 1 and 2 Standardized Plant Analysis Risk (SPAR) model determined that the increase in risk associated with the proposed elimination of an automatic isolation function from high TE MSL tunnel temperature is sufficiently low and within the risk acceptance guidelines in NRC Regulatory Guide 1.174, Revision 3.

3.7 Summary

The NRC staff finds the proposed changes to the Limerick TS acceptable because of the following:

Function 1.g from the various TS tables would be unlikely to serve its original purpose of isolating MSL because early detection that can be completed by the licensee provides margin to the critical crack size being reached. The proposed TS 3.7.9 would require a

plant shutdown if a leak is detected, and other Functions 1.a and 1.c through 1.f would continue to provide MSL isolation. GDCs 30 and 54 continue to be satisfied.

The dose limits are bounded by the existing DBA and transient analyses; therefore, 10 CFR 20.1301 continues to be satisfied.

The proposed TS 3.7.9 meets the requirements of 10 CFR 50.36(c)(2) and 10 CFR 50.36(c)(3), as discussed in section 3.5 of this safety evaluation.

The available risk insights related to the proposed elimination of an automatic isolation function are acceptable for the purposes of supporting the deterministic evaluation.

Therefore, the NRC staff finds the proposed revision to TS tables 3.3.2-1, 3.3.2-2, 3.3.2-3, and 4.3.2.1-1 to eliminate the requirement for automatic MSL isolation on high TE MSL tunnel temperature (Function 1.g) acceptable. The NRC staff also finds the proposed new TS 3.7.9, which would require monitoring the TE MSL tunnel area temperature and a plant shut down if excessive MSL leakage is detected, acceptable.

4.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION

The NRCs regulation in 10 CFR 50.92(c) states that the NRC may make a final determination, under the procedures in 10 CFR 50.91, that a license amendment involves NSHC if operation of the facility, in accordance with the amendment, w ould not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

In its LAR, the licensee provided its analysis that the proposed amendments involve NSHC. The licensees evaluation of the issue of NSHC is presented below:

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No

The proposed changes do not alter any of the previously evaluated accidents in the UFSAR. The proposed changes do not affect any of the initiators of previously evaluated accidents in a manner that would increase the likelihood of the event. The proposed change also eliminates the automatic MSIV isolation function associated with TE MSL Tunnel high temperature from the requirements of the Technical Specifications (TS) and creates TS requirements for TE MSL tunnel temperature monitoring in a new TS 3/4.7.9.

Automatic isolation of the MSIVs on TE MSL tunnel high temperature is not an initiator of any accident previously evaluated. A manual plant shutdown initiated due to MSL leakage in the TE MSL tunnel is not an initiator of any accident previously evaluated. There is no credit taken in any licensing basis analysis for MSIV closure on TE MSL tunnel high temperature, and there are no calculations that credit the subject isolation function as a mitigative feature.

As a result, the likelihood of malfunction of an SSC is not increased. The capability and operation of the mitigation systems are not affected by the proposed changes. Thus, the mitigating systems will continue to be initiated and mitigate the consequences of an accident as assumed in the analysis of accidents previously evaluated.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No

The proposed changes will not introduce any new operating modes, safety-related equipment lineups, accident scenarios, system interactions, or failure modes that would create a new or different type of accident. Failure(s) of the system will have the same effect as the present design.

The proposed change also eliminates the automatic MSIV isolation function associated with TE MSL Tunnel high temperature from the requirements of the TS and creates TS requirements for TE MS L tunnel temperature monitoring in a new TS 3/4.7.9. Eliminating the automatic isolation of the MSIVs will not create a new or different kind of accident from those previously evaluated as a Main Steam Line Break has been evaluated. Elimination of the automatic isolation function will not create a new failure mechanism as a plant shutdown continues to be required if an MSL leak is detected.

The proposed change from an automatic shutdown to a manual shutdown will not create any credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases. The unlikely failure to manually detect an MSL leak and shutdown the plant and that failure leading to a Main Steam Line Break has already been evaluated and is not a new type of accident.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No

The proposed changes do not affect the accident source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of any accident previously evaluated and are consistent with safety analysis assumptions and resultant consequences. The proposed changes do not impact reactor operating parameters or the functional requirements of the affected instrumentation systems. These systems will continue to provide the design basis reactor trips and protective system actuations. All design basis events, and the reliance on the reactor trips and protective system actuations will remain unchanged. No controlling numerical

values for parameters established in the UFSAR or the license or Safety Limits are affected by the proposed changes.

Based on NRCs review of the licensees evaluation, the NRC staff finds that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff has made a final determination that NSHC is involved for the proposed amendment and that the amendment should be issued as allowed by the criteria contained in 10 CFR 50.91.

5.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Commonwealth of Pennsylvania official was notified of the proposed issuance of the amendments on July 3, 2024. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve 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 amendments involve NSHC published in the Federal Register on June 25, 2024 (89 FR 53124), and there has been no public comment on such finding. Section 4.0 of this safety evaluation contains the NRCs final NSHC determination. Accordingly, the amendments meet 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 amendments.

7.0 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 Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

8.0 PRINCIPAL CONTRIBUTORS

Derek Scully, Office of Nuclear Reactor Regulation David McClain, Office of Nuclear Reactor Regulation Elena Herrera, Office of Nuclear Reactor Regulation

Date: July 29, 2024

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