ML15218A501

Limerick Generating Station, Unit Nos. 1 and 2 - Issuance of Amendment Nos. 219 and 181 Proposed Change to Add New Limiting Conditions for Operation 3.0.5 and 3.0.6 (TAC Nos. MF5133 and MF5134)

ML15218A501
Person / Time
Site:	Limerick
Issue date:	09/15/2015
From:	Richard Ennis Plant Licensing Branch 1
To:	Bryan Hanson Exelon Nuclear
Ennis R B, NRR/DORL/LPLI-2
References
TAC MF5133, TAC MF5134
Download: ML15218A501 (32)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 WASHINGTON, D.C. 20555-0001 September 15, 2015

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 -ISSUANCE OF AMENDMENTS RE: PROPOSED CHANGE TO ADD NEW LIMITING CONDITIONS FOR OPERATION 3.0.5 AND 3.0.6 (TAC NOS. MF5133 AND MF5134)

Dear Mr. Hanson:

The Commission has issued the enclosed Amendment Nos. 219 and 181 to Renewed Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station, Units 1 and 2, respectively, in response to your application dated November 3, 2014, as supplemented by letter dated April 14, 2015. The amendments add new Limiting Conditions for Operation (LCOs) 3.0.5 and 3.0.6 to the Applicability section of the Technical Specifications (TSs). LCO 3.0.5 establishes an allowance for restoring equipment to service under administrative controls when the equipment has been removed from service or declared inoperable to comply with TS Action requirements.

LCO 3.0.6 provides actions to be taken when the inoperability of a support system results in the inoperability of the related supported systems. In addition, the amendments add the Safety Function Determination Program to the Administrative Controls section of the TSs. This program is intended to ensure that a loss of safety function is detected and appropriate actions are taken when LCO 3.0.6 is entered.

B. Hanson A copy of the related safety evaluation is also enclosed.

Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Docket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 219 to Renewed NPF-39 2. Amendment No. 181 to Renewed NPF-85 3. Safety Evaluation cc w/enclosures:

Distribution via Listserv Sincerely, Richard B. Ennis, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-352 LIMERICK GENERATING STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 219 Renewed License No. NPF-39 1. The Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Exelon Generation Company, LLC (the licensee), dated November 3, 2014, as supplemented by letter dated April 14, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; 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 Commission's 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 1 O CFR Part 51 of the Commission's 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. 219, 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.

Attachment:

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

September 15, 2015 FOR THE NUCLEAR REGULATORY COMMISSION

'1;; vf: /:dJ &" glas A. Broaddus, Chief ant Licensing Branch 1-2 ivision of Operating Reactor Licensing Office of Nuclear Reactor Regulation ATTACHMENT TO LICENSE AMENDMENT NO. 219 RENEWED FACILITY OPERATING LICENSE NO. NPF-39 DOCKET NO. 50-352 Replace the following page of the Renewed Facility Operating License with the revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change. Remove 3 Insert 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 xxviii 3/4 0-1 3/4 3-1 6-23 Insert xxviii 3/4 0-1 3/4 0-1 a 3/4 3-1 6-23 6-24 (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 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 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 license shall be completed as specified.

Attachment 1 is hereby incorporated into this 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. 219, are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. Amendment No. 219 ADMINISTRATIVE CONTROLS SECTION PAGE 6.13 PROCESS CONTROL PROGRAM (PCP) ....................................

6-21 6.14 OFFSITE DOSE CALCULATION MANUAL (QDCMl ...........................

6-22 6.15 (Deleted)

........................................................

6-22 6.16 CONTROL ROOM ENVELOPE HABITABILITY PROGRAM .......................

6-22 6.17 SAFETY FUNCTION DETERMINATION PROGRAM (SFDP) .....................

6-23 LIMERICK -UNIT 1 xxviii Amendment No . .4g, -+/-gg, 219 314.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.l Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL CONDITIONS or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met, except as provided in Specifications 3.0.5 and 3.0.6. 3.0.2 Noncompliance with a Specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals, except as provided in Specifications 3.0.5 and 3.0.6. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in an OPERATIONAL CONDITION in which the Specification does not apply by placing it, as applicable, in: a. At least STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, b. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and c. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation.

Exceptions to these requirements are stated in the individual Specifications.

This Specification is not applicable in OPERATIONAL CONDITION 4 or 5. 3.0.4 When a Limiting Condition for Operation is not met, entry into an OPERATIONAL CONDITION or other specified condition in the Applicability shall only be made: a. When the associated ACTION requirements to be entered permit continued operation in the OPERATIONAL CONDITION or other specified condition in the Applicability for an unlimited period of time; or b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the OPERATIONAL CONDITION or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications; or c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in OPERATIONAL CONDITIONS or other specified conditions in the Applicability that are required to comply with ACTION requirements or that are part of a shutdown of the unit. LIMERICK -UNIT 1 314 0-1 Amendment No. -+/--+/-, -+/--9-9-, 219 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION (Continued) 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONs may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment.

This is an exception to the second premise of Specification 3.0.1 and is an exception to Specification 3.0.2 (i.e., to not comply with the applicable ACTION(s))

for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

3.0.6 When a supported system Limiting Condition for Operation is not met solely due to a support system Limiting Condition for Operation not being met, the ACTIONS associated with this supported system are not required to be entered. Only the support system Limiting Condition for Operation ACTIONs are required to be entered. This is an exception to the second premise of Specification 3.0.l and is an exception to Specification 3.0.2 (i.e., to not comply with the applicable ACTION(s))

for the supported system. In this event, an evaluation shall be performed in accordance with Specification 6.17, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the Limiting Condition for Operation in which the loss of safety function exists are required to be entered. When a support system's ACTION directs a supported system to be declared inoperable or directs entry into ACTIONs for a supported system, the applicable ACTIONS shall be entered in accordance with Specification 3.0.1. LIMERICK -UNIT 1 314 0-la Amendment No. 219 I 3/4.3 INSTRUMENTATION 3/4.3.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.1 As a minimum, the reactor protection system instrumentation channels shown in Table 3.3.1-1 shall be OPERABLE with the REACTOR PROTECTION SYSTEM RESPONSE TIME as shown in Table 3.3.1-2. APPLICABILITY:

As shown in Table 3.3.1-1. ACTION: Note: Separate condition entry is allowed for each channel. a. With the number of OPERABLE channels in either trip system for one or more Functional Units less than the Minimum OPERABLE Channels per Trip System required by Table 3.3.1-1, within one hour for each affected functional unit either verify that at least one* channel in each trip system is OPERABLE or tripped or that the trip system is tripped, or place either the affected trip system or at least one inoperable channel in the affected trip system in the tripped condition.

b. With the number of OPERABLE channels in either trip system less than the Minimum OPERABLE Channels per Trip System required by Table 3.3.1-1, place either the inoperable channel(s) or the affected trip system** in the tripped conditions within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. c. With the number of OPERABLE channels in both trip systems for one or more Functional Units less than the Minimum OPERABLE Channels per Trip System required by Table 3.3.1-1, place either the inoperable channel(s) in one trip system or one trip system in the tripped condition within 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />s**. d. lf within the allowable time allocated by Actions a, b or c, it is not desired to place the inoperable channel or trip system in trip (e.g., full scram would occur), Then no later than expiration of that allowable time initiate the action identified in Table 3.3.1-1 for the applicable Functional Unit. *For Functional Units 2.a, 2.b, 2.c, 2.d, and 2.f, at least two channels shall be OPERABLE or tripped. For Functional Unit 5, both trip systems shall have each channel associated with the MSIVs in three main steam lines (not necessarily the same main steam lines for both trip systems) OPERABLE or tripped. For Function 9, at least three channels per trip system shall be OPERABLE or tripped. **For Functional Units 2.a, 2.b, 2.c, 2.d, and 2.f, inoperable channels shall be placed in the tripped condition to comply with Action b. Action c does not apply for these Functional Units. LIMERICK -UNIT 1 314 3-1 Amendment No .

219 ADMINISTRATIVE CONTROLS CONTROL ROOM ENVELOPE HABITABILITY PROGRAM (Continued)

c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.l and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0. d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREFAS, operating at the flow rate required by SR 4.7.2.1.c.l, at a Frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 24 month assessment of the CRE boundary.

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph

c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences.

Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis. f. The provisions of Specification 4.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

6.17 SAFETY FUNCTION DETERMINATION PROGRAM (SFDP) This program ensures loss of safety function is detected and appropriate actions taken. Upon entry into Specification 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other appropriate actions may be taken as a result of the support system inoperability and corresponding exception to entering supported system ACTIONS. This program implements the requirements of Specification 3.0.6. The SFDP shall contain the following:

a. Provisions for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected, b. Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists, c. Provisions to ensure that an inoperable supported system's Allowed Outage Time is not inappropriately extended as a result of multiple support system inoperabilities, and LIMERICK -UNIT l 6-23 Amendment No. -+/-gg, 219 ADMINISTRATIVE CONTROLS 6.17 SAFETY FUNCTION DETERMINATION PROGRAM (SFDP) (Continued)

d. Other appropriate limitations and remedial or compensatory actions. A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed.

For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and: a. A required system redundant to the system(s) supported by the inoperable support system is also inoperable, b. A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable, or c. A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the Limiting Condition for Operation in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate ACTIONs to enter are those of the support system. LIMERICK -UNIT 1 6-24 Amendment No. 219 I UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 181 Renewed License No. NPF-85 1. The Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Exelon Generation Company, LLC (the licensee), dated November 3, 2014, as supplemented by letter dated April 14, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; 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 Commission's 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 1 O CFR Part 51 of the Commission's 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. 181, 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.

Attachment:

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

September 1 s, 2015 JHE NUCLEAR REGULATORY COMMISSION uglas A. Broaddus, Chief ant Licensing Branch 1-2 ivision of Operating Reactor Licensing Office of Nuclear Reactor Regulation ATTACHMENT TO LICENSE AMENDMENT NO. 181 RENEWED FACILITY OPERATING LICENSE NO. NPF-85 DOCKET NO. 50-353 Replace the following page of the Renewed Facility Operating License with the revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change. Remove Page 3 Insert Page 3 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Remove xxviii 3/4 0-1 3/4 3-1 6-23 Insert xxviii 3/4 0-1 314 0-1 a 3/4 3-1 6-23 6-24 (4) Pursuant to the Act and 1 O 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 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 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. 181, are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. (3) Fire Protection (Section 9.5. SSER-2. -4)* Exelon Generation Company shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report for the facility, and as approved in the NRC Safety Evaluation Report dated August 1983 through Supplement 9, dated August 1989, and Safety Evaluation dated November 20, 1995, subject to the following provision:

The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. *The parenthetical notation following the title of license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Amendment No. 181 ADMINISTRATIVE CONTROLS SECTION 6.13 PROCESS CONTROL PROGRAM (PCP) ....................................

6-21 6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM) ...........................

6-22 6.15 (Deleted)

........................................................

6-22 6.16 CONTROL ROOM ENVELOPE HABITABILITY PROGRAM .......................

6-22 6.17 SAFETY FUNCTION DETERMINATION PROGRAM (SFDP) .....................

6-23 LIMERICK -UNIT 2 xxviii Amendment No. -+/--+/-, -+/-4-9, 181 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL CONDITIONS or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met, except as provided in Specifications 3.0.5 and 3.0.6. 3.0.2 Noncompliance with a Specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals, except as provided in Specifications 3.0.5 and 3.0.6. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in an OPERATIONAL CONDITION in which the Specification does not apply by placing it, as applicable, in: a. At least STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, b. At 1 east HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and c. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation.

Exceptions to these requirements are stated in the individual Specifications.

This Specification is not applicable in OPERATIONAL CONDITION 4 or 5. 3.0.4 When a Limiting Condition for Operation is not met, entry into an OPERATIONAL CONDITION or other specified condition in the Applicability shall only be made: a. When the associated ACTION requirements to be entered permit continued operation in the OPERATIONAL CONDITION or other specified condition in the Applicability for an unlimited period of time; or b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the OPERATIONAL CONDITION or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications; or c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in OPERATIONAL CONDITIONS or other specified conditions in the Applicability that are required to comply with ACTION requirements or that are part of a shutdown of the unit. LIMERICK -UNIT 2 3/4 0-1 Amendment No. 181 314.0 APPLICABILITY llMITING CONDITION FOR OPERATION (Continued) 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONs may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment.

This is an exception to the second premise of Specification 3.0.1 and is an exception to Specification 3.0.2 (i.e., to not comply with the applicable ACTION(s))

for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

3.0.6 When a supported system Limiting Condition for Operation is not met solely due to a support system Limiting Condition for Operation not being met, the ACTIONs associated with this supported system are not required to be entered. Only the support system Limiting Condition for Operation ACTIONs are required to be entered. This is an exception to the second premise of Specification 3.0.1 and is an exception to Specification 3.0.2 (i.e., to not comply with the applicable ACTION(s))

for the supported system. In this event, an evaluation shall be performed in accordance with Specification 6.17, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the Limiting Condition for Operation in which the loss of safety function exists are required to be entered. When a support system's ACTION directs a supported system to be declared inoperable or directs entry into ACTIONs for a supported system, the applicable ACTIONS shall be entered in accordance with Specification 3.0.1. LIMERICK -UNIT 2 314 0-la Amendment No. 181 3/4.3 INSTRUMENTATION 3/4.3.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.1 As a minimum, the reactor protection system instrumentation channels shown in Table 3.3.1-1 shall be OPERABLE with the REACTOR PROTECTION SYSTEM RESPONSE TIME as shown in Table 3.3.1-2. APPLICABILITY:

As shown in Table 3.3.1-1. ACTION: Note: Separate condition entry is allowed for each channel. a. With the number of OPERABLE channels in either trip system for one or more Functional Units less than the Minimum OPERABLE Channels per Trip System required by Table 3.3.1-1, within one hour for each affected functional unit either verify that at least one* channel in each trip system is OPERABLE or tripped or that the trip system is tripped, or place either the affected trip system or at least one inoperable channel in the affected trip system in the tripped condition.

b. With the number of OPERABLE channels in either trip system less than the Minimum OPERABLE Channels per Trip System required by Table 3.3.1-1, place either the inoperable channel(s) or the affected trip system** in the tripped condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. c. With the number of OPERABLE channels in both trip systems for one or more Functional Units less than the Minimum OPERABLE Channels per Trip System required by Table 3.3.1-1, place either the inoperable channel(s) in one trip system or one trip system in the tripped condition within 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />s**. d. 11 within the allowable time allocated by Actions a, b or c, it is not desired to place the inoperable channel or trip system in trip (e.g., full scram would occur), Then no later than expiration of that allowable time initiate the action identified in Table 3.3.1-1 for the applicable Functional Unit.

• For Functional Units 2.a, 2.b, 2.c, 2.d, and 2.f, at least two channels shall be OPERABLE or tripped. For Functional Unit 5, both trip systems shall have each channel associated with the MSIVs in three main steam lines (not necessarily the same main steam lines for both trip systems) OPERABLE or tripped. For Function 9, at least three channels per trip system shall be OPERABLE or tripped. ** For Functional Units 2.a, 2.b, 2.c, 2.d, and 2.f, inoperable channels shall be placed in the tripped condition to comply with Action b. Action c does not apply for these Functional Units. LIMERICK -UNIT 2 3/4 3-1 Amendment No.

181 ADMINISTRATIVE CONTROLS CONTROL ROOM ENVELOPE HABITABILITY PROGRAM (Continued)

c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.l and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0. d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREFAS, operating at the flow rate required by SR 4.7.2.1 c.1, at a Frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 24 month assessment of the CRE boundary.

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph

c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences.

Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis. f. The provisions of Specification 4.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

6.17 SAFETY FUNCTION DETERMINATION PROGRAM (SFDP) This program ensures loss of safety function is detected and appropriate actions taken. Upon entry into Specification 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other appropriate actions may be taken as a result of the support system inoperability and corresponding exception to entering supported system ACTIONs. This program implements the requirements of Specification 3.0.6. The SFDP shall contain the following:

a. Provisions for cross train checks to ensure a loss of the capability to perform the safety function assumed in the accident analysis does not go undetected, b. Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists, c. Provisions to ensure that an inoperable supported system's Allowed Outage Time is not inappropriately extended as a result of multiple support system inoperabilities, and LIMERICK -UNIT 2 6-23 Amendment No. -+/-4-9-, 181 ADMINISTRATIVE CONTROi S 6.17 SAFETY FUNCTION DETERMINATION PROGRAM (SFDP) (Continued)

d. Other appropriate limitations and remedial or compensatory actions. A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed.

For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and: a. A required system redundant to the system(s) supported by the inoperable support system is also inoperable, b. A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable, or c. A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate ACTIONS of the Limiting Condition for Oper9tion in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate ACTIONS to enter are those of the support system. LIMERICK -UNIT 2 6-24 Amendment No. 181 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 219 AND 181 TO RENEWED FACILITY OPERATING LICENSE NOS. NPF-39 AND 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 November 3, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 14308A144), as supplemented by letter dated April 14, 2015 (ADAMS Accession No. ML 15104A526), Exelon Generation Company, LLC (Exelon, the licensee), requested changes to the Technical Specifications

{TSs) for Limerick Generating Station (LGS), Units 1 and 2. Specifically, the amendments would add Limiting Conditions for Operation (LCOs) 3.0.5 and 3.0.6 to the Applicability section of the TSs. LCO 3.0.5 would establish an allowance for restoring equipment to service, under administrative controls, when the equipment has been removed from service or declared inoperable to comply with TS Action requirements.

LCO 3.0.6 would provide actions to be taken when the inoperability of a support system results in the inoperability of the related supported systems. In addition, the proposed amendments would add the TS 6.17, "Safety Function Determination Program (SFDP)" to the Administrative Controls section of the TSs. This program is intended to ensure that a loss of safety function is detected and appropriate actions are taken when LCO 3.0.6 is entered. The proposed amendments would also revise the TS Index to reflect the addition of the SFDP. In addition, changes would be made to existing LCOs 3.0.1, 3.0.2 and 3.3.1 related to the addition of LCOs 3.0.5 and 3.0.6. The specific TS changes are discussed below in safety evaluation (SE) Section 3.1. The supplement dated April 14, 2015, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC or the Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on December 23, 2014 (79 FR 77046). Enclosure 3 2.0 REGULATORY EVALUATION The NRC's regulatory requirements related to the content of the TSs are set forth in Title 1 O of the Code of Federal Regulations (1 O CFR) Section 50.36, "Technical specifications." This regulation requires that the TSs include items in the following five specific categories:

(1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls.

The regulation does not specify the particular requirements to be included in a plant's TSs. As discussed in 1 O CFR 50.36(c)(2), LCOs are the lowest functional capability or performance level of equipment required for safe operation of the facility.

When LCOs are not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the LCO can be met. As discussed in 10 CFR 50.36(c)(5), administrative controls are the provisions relating to the organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. In general, there are two classes of changes to TSs: (1) changes needed to reflect modifications to the design basis (TSs are derived from the design basis), and (2) voluntary changes to take advantage of the evolution in policy and guidance as to the required content and preferred format of TSs over time. The proposed amendments relate to the second class of changes. Specifically, the proposed changes are based on TS improvements contained in the generically-approved guidance in NUREG-1433, Revision 4.0, "Standard Technical Specifications, General Electric BWR [Boiling Water Reactor]/4 Plants" (ADAMS Accession No. ML 12104A 192). The NRC staff used the guidance in the Standard Technical Specifications (STS) (i.e., NUREG-1433) in evaluating the proposed amendments.

3.0 TECHNICAL EVALUATION 3.1 Proposed TS Changes The licensee proposed the following TS changes for LGS, Units 1 and 2: (1) Add new LCO 3.0.5, which would read as follows: Equipment removed from service or declared inoperable to comply with ACTIONs may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment.

This is an exception to the second premise of Specification 3.0.1 and is an exception to Specification 3.0.2 (i.e., to not comply with the applicable ACTION(s))

for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

(2) Add new LCO 3.0.6, which would read as follows: When a supported system Limiting Condition for Operation is not met solely due to support system Limiting Condition for Operation not being met, the ACTIONs associated with this supported system are not required to be entered. Only the support system Limiting Condition for Operation ACTIONs are required to be entered. This is an exception to the second premise of Specification 3.0.1 and is an exception to Specification 3.0.2 (i.e., to not comply with the applicable ACTION(s))

for the supported system. In this event, an evaluation shall be performed in accordance with Specification 6.17, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the Limiting Condition for Operation in which the loss of safety function exists are required to be entered. When a support system's ACTION directs a supported system to be declared inoperable or directs entry into ACTIONs for a supported system, the applicable ACTIONs shall be entered in accordance with Specification 3.0.1. (3) Revise LCO 3.0.1 to add the words "except as provided in Specifications 3.0.5 and 3.0.6" to indicate that new LCOs 3.0.5 and 3.0.6 are an exception to LCO 3.0.1. (4) Revise LCO 3.0.2 to add the words "except as provided in Specifications 3.0.5 and 3.0.6" to indicated that new LCOs 3.0.5 and 3.0.6 are an exception to LCO 3.0.2. (5) Revise LCO 3.3.1, to delete footnote "***" and its associated references in LCO Actions "b" and "c." (6) Add new TS 6.17, "Safety Function Determination Program (SFDP)," to the Administrative Controls section of the TSs. (7) Revise TS Index page xxviii to reflect the addition of new TS 6 .17. The proposed changes are evaluated below in SE Sections 3.2 through 3.7. 3.2 Addition of LCO 3.0.5 In its application dated November 3, 2014, the licensee originally proposed the following language for new LCO 3.0.5: Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment.

This is an exception to Specifications 3.0.1 and 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

In its letter dated April 14, 2015, the licensee provided a response to an NRC staff request for additional information (RAI) in regard to the proposed amendments.

One of the staff RAI questions noted that STS LCOs 3.0.5 and 3.0.6 only have LCO 3.0.2 listed as an exception.

However, in the application dated November 3, 2014, the proposed LCOs 3.0.5 and 3.0.6 for LGS identified LCOs 3.0.1 and 3.0.2 as exceptions.

The staff requested the licensee to explain the differences between the proposed new LCOs 3.0.5 and 3.0.6 for LGS and the same LCOs in NUREG-1433, Revision 4. The licensee's response to the staff's RAI stated, in part, that: The existing LGS TS LCO 3.0.1 includes essentially the same requirements as STS LCOs 3.0.1 and 3.0.2. Exelon acknowledges that the addition of LCOs 3.0.5 and 3.0.6 requires an exception to only the second premise of the existing LGS TS LCO 3.0.1 {which correlates to STS LCO 3.0.2), that states: " ... except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met," as well as LGS TS LCO 3.0.2. The proposed TS Bases for LCO 3.0.5 included in the original license amendment request as Attachment 3 acknowledged this distinction by including a statement that the sole purpose of Specification 3.0.5 is to provide an exception to Specifications 3.0.1 and 3.0.2 (i.e., to not comply with the applicable ACTION(s))

to allow the performance of required testing to demonstrate the operability of the equipment being returned to service, or the operability of other equipment.

However, rather than just making a statement in the TS Bases, in order to more clearly make the distinction that the exception only applies to the second premise of TS LCO 3.0.1, Exelon proposes to revise the proposed TS LCO 3.0.5 and 3.0.6 wording to say: "This is an exception to the second premise of Specification 3.0.1 and is an exception to Specification 3.0.2 (i.e., to not comply with the applicable ACTION(s))

... " In the licensee's RAI response, the licensee also stated that the changes proposed in the amendment request maintain consistency with NUREG-1433.

Additionally, the language in the revised LGS TS LCOs 3.0.5 and 3.0.6 do not introduce any changes, either in the technical requirements or in the TS usage rules, from the language used in the STSs. As a result of the NRC staff's RAI, the proposed new LCO 3.0.5 for LGS would read as follows, as shown in the licensee's letter dated April 14, 2015: Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment.

This is an exception to the second premise of Specification 3.0.1 and is an exception to Specification 3.0.2 (i.e., to not comply with the applicable ACTION(s))

for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.5 would establish an exception to the second premise of LGS LCO 3.0.1, which states, in part, "except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met," as well as an exception to LCO 3.0.2 to not comply with applicable actions. The addition of the LCO would allow for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with TS Action requirements.

The licensee stated in its application dated November 3, 2014, that administrative controls, such as test procedures, would ensure that the time the equipment is returned to service, in conflict with the TS Action requirements, is limited to the time necessary to perform the required testing to demonstrate operability.

The proposed LCO would not provide time to perform other preventative or corrective maintenance.

The licensee further stated that the potential impact of temporarily returning the equipment to service, for the purpose of confirming operability, is considered insignificant since the equipment would be expected to be able to perform its safety function.

For those times when equipment, which may be temporarily returned to service under administrative controls, is subsequently determined to remain inoperable, the resulting condition is comparable to the equipment having been determined to be inoperable during operation, with continued operation for a specified time allowed to complete required TS actions. Based on the above considerations, the NRG staff finds that the proposed new LCO 3.0.5 for LGS would provide acceptable means for restoration of equipment that is inoperable or is removed from service due to TS requirements, in order to allow testing of that or other equipment.

Therefore, the NRG staff concludes that the addition of LCO 3.0.5 is acceptable.

3.3 Addition of LCO 3.0.6 In its application dated November 3, 2014, the licensee originally proposed the following language for new LCO 3.0.6: When a supported system Limiting Condition for Operation is not met solely due to a support system Limiting Condition for Operation not being met, the ACTIONs associated with this supported system are not required to be entered. Only the support system Limiting Condition for Operation ACTIONs are required to be entered. This is an exception to Specifications 3.0.1 and Specification 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 6.17, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the Limiting Condition for Operation in which the loss of safety function exists are required to be entered. When a support system's ACTION directs a supported system to be declared inoperable or directs entry into ACTIONS for a supported system, the applicable ACTIONs shall be entered in accordance with Specification 3.0.1. As discussed above in SE Section 3.2, in its RAI response dated April 14, 2015, the licensee provided further information to explain the differences between the proposed new LCOs 3.0.5 and 3.0.6 for LGS and the same LCOs in NUREG-1433, Revision 4. As a result of the NRG staff's RAI, the proposed new LCO 3.0.6 for LGS would read as follows, as shown in the licensee's letter dated April 14, 2015: When a supported system Limiting Condition for Operation is not met solely due to a support system Limiting Condition for Operation not being met, the ACTIONS associated with this supported system are not required to be entered. Only the support system Limiting Condition for Operation ACTIONs are required to be entered. This is an exception to the second premise of Specification 3.0.1 and is an exception to Specification 3.0.2 (i.e., to not comply with the applicable ACTION(s))

for the supported system. In this event, an evaluation shall be performed in accordance with Specification 6.17, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate ACTIONs of the Limiting Condition for Operation in which the loss of safety function exists are required to be entered. When a support system's ACTION directs a supported system to be declared inoperable or directs entry into ACTIONS for a supported system, the applicable ACTIONs shall be entered in accordance with Specification 3.0.1. LCO 3.0.6 would establish an exception to the second premise of LGS LCO 3.0.1, and is an exception to LCO 3.0.2 to not comply with the applicable actions for the supported system. This exception is provided because LCOs 3.0.1 and 3.0.2 would require that the conditions and required actions of the associated LCO for the inoperable supported system LCO be entered solely due to the inoperability of the support system. This exception is justified because the actions that are required to ensure the plant is maintained in a safe condition are specified in the support system LCO's required actions. These required actions may include entering the supported system's conditions and required actions or may specify other required actions. When a support system is inoperable and there is an LCO specified for it in the TSs, the supported system(s) are required to be declared inoperable if determined to be inoperable as a result of the support system inoperability.

However, with LCO 3.0.6, it is not necessary to enter into the supported system's conditions and required actions unless directed to do so by the support system's required actions. There are instances where a support system's required action may either direct a supported system to be declared inoperable or direct entry into conditions and required actions for the supported system. When a support system's required action directs a supported system to be declared inoperable or directs entry into conditions and required actions for a supported system, the applicable conditions and required actions shall be entered in accordance with LGS LCO 3.0.1. The NRC staff finds that the proposed addition of LCO 3.0.6 to the LGS TSs would eliminate potential confusion and inconsistency of requirements related to the entry into multiple support and supported systems' LCO conditions and required actions by providing all the actions that are necessary to ensure the plant is maintained in a safe condition in the support system's required actions. Based on these considerations, the NRC staff concludes that the addition of LCO 3.0.6 is acceptable.

3.4 Revision to LCOs 3.0.1 and 3.0.2 LGS TS LCO 3.0.1 currently states: Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL CONDITIONS or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met. LGS TS LCO 3.0.2 currently states: Noncompliance with a Specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals.

If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

LCO 3.0.1 currently requires that the action requirements for an LCO must be met upon failure to meet the LCO. LCO 3.0.2 currently states that a noncompliance with a specification exists when the requirements of the LCO and associated action requirements are not met within the specified time interval.

Proposed new LCOs 3.0.5 and 3.0.6 would be exceptions to LCOs 3.0.1 and 3.0.2. As such, the licensee has proposed to add the statement "except as provided in Specifications 3.0.5 and 3.0.6" to LCOs 3.0.1 and 3.0.2. The proposed revision to LCO 3.0.1 would read as follows: Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL CONDITIONS or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met, except as provided in Specifications 3.0.5 and 3.0.6. The proposed revision to LCO 3.0.2 would read as follows: Noncompliance with a Specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals, except as provided in Specifications 3.0.5 and 3.0.6. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

Since the new proposed LCOs 3.0.5 and 3.0.6 are exceptions to LCOs 3.0.1 and 3.0.2, LCOs 3.0.1 and 3.0.2 need to be modified accordingly to reference the new LCOs as exceptions.

The NRC staff finds that proposed changes to LCOs 3.0.1 and 3.0.2 are necessary in order for the licensee to apply the exceptions allowed by LCOs 3.0.5 and 3.0.6. As discussed above in SE Sections 3.2 and 3.3, the NRC staff concluded that the new proposed LCOs 3.0.5 and 3.0.6 are acceptable.

Accordingly, the staff concludes that the proposed changes to LCOs 3.0.1 and 3.0.3 are also acceptable.

3.5 Deletion of LCO 3.3.1 Footnote LGS TS 3/4.3.1, "Reactor Protection System Instrumentation," contains a footnote designated as "***" that pertains to LCO 3.3.1 Actions "b" and "c." The footnote reads as follows: A channel or trip system which has been placed in the tripped condition to satisfy Action b. or c. may be returned to the untripped condition under administrative control for up to two hours solely to perform testing required to demonstrate its operability or the operability of other equipment provided Action a. continues to be satisfied.

The licensee proposed to delete this footnote since it is essentially duplicative to the provisions in the proposed new LCO 3.0.5. The NRC staff finds that the proposed new LCO 3.0.5 would allow the same exception currently stated in LCO 3.3.1 footnote"***." Therefore, the staff concludes that the proposed deletion of the footnote is acceptable. 3.6 Addition of TS 6.17, "Safety Function Determination Program (SFDP)" The licensee proposed to add TS 6.17, "Safety Function Determination Program (SFDP)," to the Administrative Controls section of the LGS TSs. In accordance with the SFDP, upon entry into LCO 3.0.6, the licensee is required to make an evaluation to determine if a loss of safety function exists. Additionally, the SFDP could identify other limitations, remedial actions, or compensatory actions as a result of the support system inoperability, as well as a corresponding exception to entering supported system conditions and required actions. In brief, the SFDP implements the requirements of LCO 3.0.6. Therefore, in conjunction with the evaluation in Section 3.3 of this SE, the NRC staff concludes that the addition of TS 6.17 is acceptable.

3.7 Revision to TS Index to Add TS 6.17 The licensee proposed to add TS 6.17 to the LGS TS Index. The NRC staff finds that this change is administrative in nature. Therefore the proposed addition of TS 6.17 to the TS Index is acceptable.

3.8 Technical Evaluation Conclusion Based on the discussion in SE Sections 3.1 through 3.7, the NRC staff concludes that the proposed amendments are acceptable.

The licensee's application dated November 3, 2014, also provided proposed changes to the TS Bases to be implemented with the associated TS changes discussed above. The TS Bases pages were provided for information only and will be revised in accordance with the TS Bases Control Program.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments.

The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The 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 no significant hazards consideration, and there has been no public comment on such finding (79 FR 77046; December 23, 2014). In addition, the amendments relate to changes in recordkeeping, reporting, or administrative procedures or requirements.

Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(10).

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 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. Principal Contributors:

C. Tilton T. Lamb R. Ennis Date: September 15, 2015 B. Hanson A copy of the related safety evaluation is also enclosed.

Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Docket Nos. 50-352 and 50-353

Enclosures:

Sincerely, IRA/ Richard 8. Ennis, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

1. Amendment No. 219 to Renewed NPF-39 2. Amendment No. 181 to Renewed NPF-85 3. Safety Evaluation cc w/enclosures:

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