ML21032A270

Issuance of Amendment Nos. 252 and 214, Revise Technical Specifications to Adopt Technical Specifications Task Force Traveler TSTF-582, Revision 0, RPV WIC Enhancements

ML21032A270
Person / Time
Site:	Limerick
Issue date:	02/22/2021
From:	V Sreenivas Plant Licensing Branch 1
To:	Rhoades D Exelon Nuclear, Exelon Generation Co
Sreenivas V, NRR/DORL/LPLI, 415-2597
References
EPID L-2020-LLA-0199, TSTF-582
Download: ML21032A270 (32)

Text

February 22, 2021 Mr. David P. Rhoades Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 ISSUANCE OF AMENDMENT NOS. 252 AND 214 RE: TECHNICAL SPECIFICATION CHANGES RELATED TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-582, REVISION 0, RPV WIC ENHANCEMENTS (EPID L-2020-LLA-0199)

Dear Mr. Rhoades:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 252 and 214 to Renewed Facility Operating License Nos. NPF-39 and NPF-85 for the Limerick Generating Station, Units 1 and 2 (Limerick), respectively, in response to your application dated September 3, 2020.

The amendments revise the technical specifications related to reactor pressure vessel (RPV) water inventory control (WIC) based on Technical Specifications Task Force (TSTF) Traveler TSTF-582, Revision 0, RPV WIC Enhancements, and the associated NRC staff safety evaluation for TSTF-582.

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

Sincerely,

/RA/

V. Sreenivas, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 252 to Renewed NPF-39

2. Amendment No. 214 to Renewed NPF-85

3. Safety Evaluation cc: Listserv

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-352 LIMERICK GENERATING STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 252 Renewed License No. NPF-39

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

A. The application for amendment by Exelon Generation Company, LLC (Exelon Generation Company), dated September 3, 2020, 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 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. 252, are hereby incorporated into this renewed license. Exelon Generation Company 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 within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by James G. James G. Danna Date: 2021.02.22 Danna 14:14:17 -05'00' James G. Danna, 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: February 22, 2021

ATTACHMENT TO LICENSE AMENDMENT NO. 252 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 Page Insert Page 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 a marginal line indicating the areas of change.

Remove Page Insert Page 1-2a 1-2a 3/4 3-41a 3/4 3-41a 3/4 3-41b 3/4 3-41b 3/4 3-41c 3/4 3-41c 3/4 3-41d 3/4 3-41d 3/4 3-41e 3/4 3-41e 3/4 5-6a 3/4 5-6a 3/4 5-7 3/4 5-7

(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 Commissions 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 Exelon Generation Company 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. 252, are hereby incorporated into this renewed license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Renewed License No. NPF-39 Amendment No. 252

DEFINITIONS DRAIN TIME (Continued) susceptible to a common mode failure, for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; d) No additional draining events occur; and e) Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

1.10 (Deleted)

EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME 1.11 The EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS actuation set-point at the channel sensor until the ECCS equipment is capable of performing its safety function, i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc. Times shall include diesel generator starting and sequence loading delays where applicable. The response time may be measured by any series of sequential, overlapping or total steps such that the entire response time is measured.

LIMERICK - UNIT 1 1-2a Amendment No. 37, 66, 87, 174, 185, 227 252

INSTRUMENTATION 3/4.3.3.A REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL (WIC) INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.A The RPV Water Inventory Control (WIC) instrumentation channels shown in Table 3.3.3.A-1 shall be OPERABLE.

APPLICABILITY: As shown in Table 3.3.3.A-1 ACTION:

a. With one or more channels inoperable in a trip system, take the ACTION referenced in Table 3.3.3.A-1 for the trip system.

SURVEILLANCE REQUIREMENTS 4.3.3.1.A Each RPV Water Inventory Control (WIC) instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL FUNCTIONAL TEST as shown in Table 4.3.3.A-1 and at the frequencies specified in the Surveillance Frequency Control Program unless otherwise noted in Table 4.3.3.A-1.

LIMERICK - UNIT 1 3/4 3-41a Amendment No. 227, 252

TABLE 3.3.3.A-1 RPV WATER INVENTORY CONTROL (WIC) INSTRUMENTATION MINIMUM OPERABLE CHANNELS PER APPLICABLE TRIP OPERATIONAL TRIP FUNCTION FUNCTION CONDITIONS ACTION

1. DELETED

2. DELETED

3. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a. Reactor Vessel Water Level -

Low - Level 3 2 in one (b) 38 trip system

4. REACTOR WATER CLEANUP SYSTEM ISOLATION

a. Reactor Vessel Water Level -

Low, Low - Level 2 2 in one (b) 38 trip system (a) DELETED (b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

(c) DELETED LIMERICK - UNIT 1 3/4 3-41b Amendment No. 227, 252

TABLE 3.3.3.A-1 (Continued)

RPV WATER INVENTORY CONTROL (WIC) INSTRUMENTATION ACTION STATEMENTS ACTION 38 - Immediately initiate action to place the channel in trip, or declare the associated trip system for the penetration flow path(s) incapable of automatic isolation and initiate action to calculate DRAIN TIME.

ACTION 39 - DELETED ACTION 40 - DELETED LIMERICK - UNIT 1 3/4 3-41c Amendment No. 227, 252

TABLE 3.3.3.A-2 RPV WATER INVENTORY CONTROL (WIC) INSTRUMENTATION SETPOINTS ALLOWABLE TRIP FUNCTION VALUE

1. DELETED

2. DELETED

3. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a. Reactor Vessel Water Level -

Low - Level 3 11.0 inches

4. REACTOR WATER CLEANUP SYSTEM ISOLATION

a. Reactor Vessel Water Level -

Low, Low - Level 2 -45 inches LIMERICK - UNIT 1 3/4 3-41d Amendment No. 227, 252

TABLE 4.3.3.A-1 RPV WATER INVENTORY CONTROL (WIC) INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL LOGIC SYSTEM OPERATIONAL CHANNEL FUNCTIONAL FUNCTIONAL CONDITIONS FOR WHICH TRIP FUNCTION CHECK(a) TEST(a) TEST(a) SURVEILLANCE REQUIRED

1. DELETED

2. DELETED

3. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a. Reactor Vessel Water Level -

Low - Level 3 N.A. (b)

4. REACTOR WATER CLEANUP SYSTEM ISOLATION

a. Reactor Vessel Water Level -

Low, Low - Level 2 N.A. (b)

(a) Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.

(b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

LIMERICK - UNIT 1 3/4 3-41e Amendment No. 227, 252

EMERGENCY CORE COOLING SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

ACTION:

c. With DRAIN TIME less than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and greater than or equal to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, within 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s:

1. Verify SECONDARY CONTAINMENT INTEGRITY is capable of being established in less than the DRAIN TIME,

2. Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME, and

3. Verify one standby gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

d. With DRAIN TIME less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, immediately:

1. Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level greater than TAF for greater than or equal to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />,***

2. Initiate action to establish SECONDARY CONTAINMENT INTEGRITY,

3. Initiate action to isolate each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room, and

4. Initiate action to verify one standby gas treatment subsystem is capable of being placed in operation.

e. With required ACTION and associated allowed outage time for ACTIONs c. or d. not met, or DRAIN TIME less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, immediately initiate action to restore DRAIN TIME to greater than or equal to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

• • • The required injection/spray subsystem or an additional method of water injection shall be capable of operating without offsite electrical power.

LIMERICK - UNIT 1 3/4 5-6a Amendment No. 227, 252

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2.1 Verify DRAIN TIME is greater than or equal to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> in accordance with the Surveillance Frequency Control Program.*

4.5.2.2 Verify, for a required LPCI subsystem, the suppression chamber water level is greater than or equal to 16 feet 0 inches in accordance with the Surveillance Frequency Control Program.

4.5.2.3 Verify, for a required CSS subsystem, that the suppression chamber water level is greater than or equal to 16 feet 0 inches or the condensate storage tank water level is greater than or equal to 29 feet 0 inches in accordance with the Surveillance Frequency Control Program.

4.5.2.4 Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

4.5.2.5 DELETED 4.5.2.6 Operate the required ECCS injection/spray subsystem for greater than or equal to 10 minutes in accordance with the Surveillance Frequency Control Program.#^

4.5.2.7 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal in accordance with the Surveillance Frequency Control Program.

4.5.2.8 Verify the required ECCS injection/spray subsystem can be manually operated in accordance with the Surveillance Frequency Control Program.

• DELETED.

1. Operation may be through the test return line.

^Credit may be taken for normal system operation to satisfy this surveillance requirement.

LIMERICK - UNIT 1 3/4 5-7 Amendment No. 95, 186, 227, 252

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 214 Renewed License No. NPF-85

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

A. The application for amendment by Exelon Generation Company, LLC (Exelon Generation Company), dated September 3, 2020, 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 2

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. 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. 214, are hereby incorporated into this renewed license. Exelon Generation Company 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 within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION James G. Digitally signed by James G. Danna Date: 2021.02.22 14:14:59 -05'00' Danna James G. Danna, 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: February 22, 2021

ATTACHMENT TO LICENSE AMENDMENT NO. 214 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 Page Insert Page 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 a marginal line indicating the areas of change.

Remove Page Insert Page 1-2a 1-2a 3/4 3-41a 3/4 3-41a 3/4 3-41b 3/4 3-41b 3/4 3-41c 3/4 3-41c 3/4 3-41d 3/4 3-41d 3/4 3-41e 3/4 3-41e 3/4 5-6a 3/4 5-6a 3/4 5-7 3/4 5-7

(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 Commissions 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 Exelon Generation Company 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. 214, are hereby incorporated into this renewed license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Renewed License No. NPF-85 Amendment No. 214

DEFINITIONS DRAIN TIME (Continued) susceptible to a common mode failure, for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; d) No additional draining events occur; and e) Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

1.10 (Deleted)

EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME 1.11 The EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS actuation set-point at the channel sensor until the ECCS equipment is capable of performing its safety function, i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.

Times shall include diesel generator starting and sequence loading delays where applicable. The response time may be measured by any series of sequential, overlapping or total steps such that the entire response time is measured.

LIMERICK - UNIT 2 1-2a Amendment No. 4, 48, 49, 136, 146, 190 214

INSTRUMENTATION 3/4.3.3.A REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL (WIC) INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.A The RPV Water Inventory Control (WIC) instrumentation channels shown in Table 3.3.3.A-1 shall be OPERABLE.

APPLICABILITY: As shown in Table 3.3.3.A-1 ACTION:

a. With one or more channels inoperable in a trip system, take the ACTION referenced in Table 3.3.3.A-1 for the trip system.

SURVEILLANCE REQUIREMENTS 4.3.3.1.A Each RPV Water Inventory Control (WIC) instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL FUNCTIONAL TEST as shown in Table 4.3.3.A-1 and at the frequencies specified in the Surveillance Frequency Control Program unless otherwise noted in Table 4.3.3.A-1.

LIMERICK - UNIT 2 3/4 3-41a Amendment No. 190, 214

TABLE 3.3.3.A-1 RPV WATER INVENTORY CONTROL (WIC) INSTRUMENTATION MINIMUM OPERABLE CHANNELS PER APPLICABLE TRIP OPERATIONAL TRIP FUNCTION FUNCTION CONDITIONS ACTION

1. DELETED

2. DELETED

3. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a. Reactor Vessel Water Level -

Low - Level 3 2 in one (b) 38 trip system

4. REACTOR WATER CLEANUP SYSTEM ISOLATION

a. Reactor Vessel Water Level -

Low, Low - Level 2 2 in one (b) 38 trip system (a) DELETED (b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

(c) DELETED LIMERICK - UNIT 2 3/4 3-41b Amendment No. 190, 214

TABLE 3.3.3.A-1 (Continued)

RPV WATER INVENTORY CONTROL (WIC) INSTRUMENTATION ACTION STATEMENTS ACTION 38 - Immediately initiate action to place the channel in trip, or declare the associated trip system for the penetration flow path(s) incapable of automatic isolation and initiate action to calculate DRAIN TIME.

ACTION 39 - DELETED ACTION 40 - DELETED LIMERICK - UNIT 2 3/4 3-41c Amendment No. 190, 214

TABLE 3.3.3.A-2 RPV WATER INVENTORY CONTROL (WIC) INSTRUMENTATION SETPOINTS ALLOWABLE TRIP FUNCTION VALUE

1. DELETED

2. DELETED

3. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a. Reactor Vessel Water Level -

Low - Level 3 11.0 inches

4. REACTOR WATER CLEANUP SYSTEM ISOLATION

a. Reactor Vessel Water Level -

Low, Low - Level 2 -45 inches LIMERICK - UNIT 2 3/4 3-41d Amendment No. 190, 214

TABLE 4.3.3.A-1 RPV WATER INVENTORY CONTROL (WIC) INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL LOGIC SYSTEM OPERATIONAL CHANNEL FUNCTIONAL FUNCTIONAL CONDITIONS FOR WHICH TRIP FUNCTION CHECK(a) TEST(a) TEST(a) SURVEILLANCE REQUIRED

1. DELETED

2. DELETED

3. RHR SYSTEM SHUTDOWN COOLING MODE ISOLATION

a. Reactor Vessel Water Level -

Low - Level 3 N.A. (b)

4. REACTOR WATER CLEANUP SYSTEM ISOLATION

a. Reactor Vessel Water Level -

Low, Low - Level 2 N.A. (b)

(a) Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.

(b) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

LIMERICK - UNIT 2 3/4 3-41e Amendment No. 190, 214

EMERGENCY CORE COOLING SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

ACTION:

c. With DRAIN TIME less than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and greater than or equal to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, within 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s:

1. Verify SECONDARY CONTAINMENT INTEGRITY is capable of being established in less than the DRAIN TIME,

2. Verify each secondary containment penetration flow path is capable of being isolated in less than the DRAIN TIME, and

3. Verify one standby gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

d. With DRAIN TIME less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, immediately:

1. Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level greater than TAF for greater than or equal to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />,***

2. Initiate action to establish SECONDARY CONTAINMENT INTEGRITY,

3. Initiate action to isolate each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room, and

4. Initiate action to verify one standby gas treatment subsystem is capable of being placed in operation.

e. With required ACTION and associated allowed outage time for ACTIONs c. or d. not met, or DRAIN TIME less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, immediately initiate action to restore DRAIN TIME to greater than or equal to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

• • • The required injection/spray subsystem or an additional method of water injection shall be capable of operating without offsite electrical power.

LIMERICK - UNIT 2 3/4 5-6a Amendment No. 190, 214

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2.1 Verify DRAIN TIME is greater than or equal to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> in accordance with the Surveillance Frequency Control Program.*

4.5.2.2 Verify, for a required LPCI subsystem, the suppression chamber water level is greater than or equal to 16 feet 0 inches in accordance with the Surveillance Frequency Control Program.

4.5.2.3 Verify, for a required CSS subsystem, that the suppression chamber water level is greater than or equal to 16 feet 0 inches or the condensate storage tank water level is greater than or equal to 29 feet 0 inches in accordance with the Surveillance Frequency Control Program.

4.5.2.4 Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

4.5.2.5 DELETED 4.5.2.6 Operate the required ECCS injection/spray subsystem for greater than or equal to 10 minutes in accordance with the Surveillance Frequency Control Program.#^

4.5.2.7 Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal in accordance with the Surveillance Frequency Control Program.

4.5.2.8 Verify the required ECCS injection/spray subsystem can be manually operated in accordance with the Surveillance Frequency Control Program.

• DELETED.

1. Operation may be through the test return line.

^Credit may be taken for normal system operation to satisfy this surveillance requirement.

LIMERICK - UNIT 2 3/4 5-7 Amendment No. 59, 147, 190 214

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 252 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-39 AND AMENDMENT NO. 214 TO RENEWED 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 application dated September 3, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20247J372), Exelon Generation Company, LLC (the licensee) submitted a license amendment request to the U.S. Nuclear Regulatory Commission (NRC, the Commission) proposing changes to the technical specifications (TSs) for Limerick Generating Station (Limerick), Units 1 and 2. The proposed changes would revise the TSs related to reactor pressure vessel (RPV) water inventory control (WIC) based on Technical Specifications Task Force (TSTF) Traveler TSTF-582, Revision 0, RPV WIC Enhancements (ADAMS Accession No. ML19240A260), and the associated NRC staff safety evaluation (SE) of TSTF-582 (ADAMS Accession No. ML20219A333).

The boiling-water reactor (BWR) RPV design includes multiple penetrations located below the top of active fuel. These penetrations provide entry for control rods, recirculation flow, reactor water cleanup, and shutdown cooling. Since these penetrations are below the top of active fuel, this creates a potential to drain the reactor vessel water inventory and lose effective core cooling. The loss of water inventory and effective core cooling can potentially lead to fuel cladding failure and radioactive release. Drain Time is the time it would take for the water inventory in and above the RPV to drain to the top of active fuel.

1.1 Proposed TS Changes to Adopt TSTF-582 In accordance with NRC-approved TSTF-582, the licensee proposed changes that would revise the TSs related to RPV WIC to incorporate operating experience and correct errors and omissions that the licensee incorporated into the Limerick TSs when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control (ADAMS Accession Enclosure 3

No. ML16074A448). Specifically, the licensee proposed the following changes to adopt TSTF-582:

The Drain Time definition in Limerick TS 1.0 would be revised to move the examples of common mode failure mechanisms to the Bases and delete seismic events.

In Limerick TS 1.0, Drain Time definition, the exception from considering the Drain Time for penetration flow paths isolated with manual or automatic valves that are locked, sealed, or otherwise secured would be revised to apply the exception for manual or automatic valves that are closed and administratively controlled.

The Actions of Limerick TS 3.3.3.A, Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation (WIC), would be revised to permit placing an inoperable isolation channel in trip as an alternative to declaring the associated penetration flow path incapable of automatic isolation.

Limerick TS 3.3.3.A, Action 38, requires calculating Drain Time with a Completion Time of immediately. The Required Action would be revised to state, Initiate action to calculate Drain Time.

Limerick TS 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control (WIC), and TS 3.3.3.A would be revised to eliminate the requirement for a manual emergency core cooling system (ECCS) initiation signal to start the required ECCS injection/spray subsystem, and instead rely on manual valve alignment and pump start. TS 3.5.2 surveillance requirements (SRs) related to manual initiation using the ECCS signal (such as verifying automatic alignment of valves on an initiation signal) would be eliminated. Related to this change, the TS 3.3.3.A functions, SRs, and Actions that only support manual initiation using an ECCS signal (including interlocks and minimum flow instruments) would be eliminated.

Limerick SR 4.5.2.6, which requires operating the required ECCS injection/spray subsystem for at least 10 minutes through the recirculation line, would be modified by the addition of two notes. The first Note would replace the existing SR that the ECCS subsystem be run through the recirculation line with a Note that states that operation may be through the test return line. The second Note would permit crediting normal operation of the low-pressure ECCS subsystem for performance of the SR.

1.2 Additional Proposed TS Changes 1.2.1 Editorial Variations Limerick TS are based on the previous version of the NRC's Standard Technical Specifications (STS) (NUREG-0123, Revision 2, Standard Technical Specifications for General Electric Boiling Water Reactors) and, therefore, the wording and format varies slightly from the NRC Improved STS (NUREG-1433,

Standard Technical Specifications: General Electric BWR/4 Plants) shown in TSTF-582, Revision 0, and the applicable parts of the NRC's safety evaluation.

Limerick uses different numbering and titles than the improved STS in several instances.

SR 4.5.2.4 is revised to correct an administrative error. The phrase in accordance with the Surveillance Frequency Control Program is proposed to be added to the end of the existing SR 4.5.2.4, which will state Verify, for the required ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

2.0 REGULATORY EVALUATION

The regulation at 10 CFR 50.36(c)(2) requires that TSs include limiting conditions for operation (LCOs). The regulation at 10 CFR 50.36(c)(2)(i) states, in part, that LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation also requires, in part, 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.

The regulation at 10 CFR 50.36(c)(3) requires that TSs include items in the category of 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 limiting conditions for operation will be met.

The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light Water Reactor] Edition (SRP), dated March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STS for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the Standard Technical Specifications, General Electric, BWR/4 Plants, NUREG-1433, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12104A192 and ML12104A193, respectively), as modified by NRC-approved travelers.

Traveler TSTF-582 revised the STSs related to RPV WIC to incorporate operating experience and to correct editorial errors in TSTF-542, Revision 2. The NRC approved TSTF-542, Revision 2, on December 20, 2016 (ADAMS Package Accession No. ML16343B066). The NRC staff approved TSTF-582 under the consolidated line item improvement process (CLIIP) in a letter dated August 13, 2020 (ADAMS Accession No. ML20219A333). The TSTF-582 SE states that a licensee may adopt the STS changes approved in TSTF-582, if the licensee has already adopted the STS changes approved in TSTF-542, Revision 2.

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes to Adopt TSTF-582 The NRC staff compared the licensees proposed TS changes in Section 1.1 of this SE against the changes approved in TSTF-582. In accordance with the SRP Chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-582 are applicable to the Limerick TSs because Limerick is a BWR/4 design and the NRC staff approved the TSTF-582 changes for BWR/4 designs. The licensee meets the TSTF-582 SE provision for adoption of TSTF-582 since it adopted traveler TSTF-542, Revision 2, dated February 27, 2018 (ADAMS Accession No. ML18017A201). Therefore, the NRC staff concludes that the licensees proposed changes to the Limerick TSs in Section 1.1 of this SE are acceptable in that they are consistent with TSTF-582 and the terms for use stated in the NRC staff SE of TSTF-582.

The NRC staff finds that the proposed changes to the TS 1.0 definition and LCOs 3.3.3.A and 3.5.2 for Limerick correctly specify the lowest functional capability or performance levels of equipment required for safe operation of the facility in accordance with 10 CFR 50.36(c)(2)(i).

Also, the NRC staff finds that the proposed changes to the Actions of LCOs 3.3.3.A and 3.5.2 for Limerick are adequate remedial actions to be taken until each LCO can be met to provide protection to the health and safety of the public, thereby satisfying 10 CFR 50.36(c)(2)(i).

The NRC staff finds that the proposed revisions to the SRs in Limerick TSs 3.3.3.A and 3.5.2 continue to provide 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 in accordance with 10 CFR 50.36(c)(3).

Thus, the proposed changes continue to meet the requirements of 10 CFR 50.36(c)(2)(i) and 50.36(c)(3) as discussed in Section 3.0 of the NRC staffs SE of TSTF-582.

3.2 Additional Proposed TS Changes The NRC staff reviewed the editorial variations proposed by the licensee as described in Section 1.2.1 of this SE.

The licensee stated that the Limerick TS are based on the previous version of the NRC's STS (NUREG-0123, Revision 2). The NRC staff reviewed the proposed changes against NRC Improved STS (NUREG-1433) shown in TSTF-582, Revision 0. The NRC staff finds this variation acceptable because the Limerick TSs meet the intent of TSTF-582, Revision 0, and does not substantively change the TS requirements.

The licensee noted that Limerick TSs have different numbering and titles than STS for the RPV WIC-related TS. The NRC staff finds that the different TS numbering changes are acceptable because they are editorial clarifications and do not substantively change TS requirements.

The licensee proposed to revise SR 4.5.2.4 to add the phrase in accordance with the Surveillance Frequency Control Program to the end of the existing SR. The licensee stated that this change is to correct an administrative error when SR 4.5.2.4 was modified as part of the TSTF-542 adoption, there was no frequency specified in the SR. Limerick has a Surveillance Frequency Control Program (SFCP) and all surveillances under TS 3.5.2 are under the SFCP as noted in the other individual TS 3.5.2 surveillances. The NRC staff reviewed the proposed change and find it acceptable because it was confirmed that all surveillances under

TS 3.5.2 are included in the SFCP. This change is editorial, and the Limerick TSs continue to meet the intent of TSTF-582, Revision 0.

Finally, the NRC staff reviewed the proposed TS changes for technical clarity and consistency with the existing requirements for customary terminology and formatting. The NRC staff finds that the proposed changes are consistent with SRP Chapter 16.0 and are therefore acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the NRC staff notified the Pennsylvania State official on February 1, 2021, of the proposed issuance of the amendments. The State official had no comments.

5.0 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 SRs.

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, which was published in the Federal Register on November 3, 2020 (85 FR 69655), that the amendments involve no significant hazards consideration, and there has been no public comment on such finding.

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.

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

Principal Contributor: T Sweat, NRR Date: February 22, 2021

ML21032A270 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC NAME VSreenivas JBurkhardt VCusumano DATE 02/1/2021 02/04/2021 01/25/2021 OFFICE NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME JDanna VSreenivas DATE 02/22/2021 2/22/2021