ML17103A081

Issuance of Amendments to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-545

ML17103A081
Person / Time
Site:	Limerick
Issue date:	05/16/2017
From:	V Sreenivas Plant Licensing Branch 1
To:	Bryan Hanson Exelon Nuclear
Sreenivas V, NRR/DORL/LPLI, 415-2597
References
CAC MF8193, CAC MF8194
Download: ML17103A081 (27)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 16, 2017 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-545 (CAC NOS. MF8193 AND MF8194)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 225 and 188 to Renewed Facility Operating License Nos. NPF-39 and NPF-85 for the Limerick Generating Station, Units 1 and 2, respectively. These amendments consist of changes to the technical specifications (TSs), specifically, changes to the TSs consistent, in part, with Technical Specifications Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF-545, Revision 3, "TS lnservice Testing Program Removal & Clarify SR [Surveillance Requirement] Usage Rule Application to Section 5.5 Testing," dated October 21, 2015, relating to the inservice inspection program required by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Code and the inservice testing program required by the ASME Code for Operation and Maintenance of Nuclear Power Plants.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

. 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. 225 to NPF-39

2. Amendment No. 188 to NPF-85

3. Safety Evaluation cc w/enclosures: Distribution via Listserv

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. 225 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 (the licensee), dated July 26, 2016, 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 10 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. 225, 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 90 days.

FOR THE NUCLEAR REGULATORY COMMISSION

- ~

~/{Mw<- u~~~

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: May 16, 2017

ATTACHMENT TO LICENSE AMENDMENT NO. 225 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 revised page.

The revised page is identified by amendment number and contains a marginal line indicating the area of change.

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

Remove Insert 1-3 1-3 3/4 0-2 3/4 0-2 3/4 0-3 3/4 0-3 3/4 6-7 3/4 6-7

(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 Commission's regulations set forth in 10 CFR Chapter I (except as exempted from compliance in Section 2.0. below) and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(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. 225, 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. 225

DEFINITIONS END-OF-CYCLE RECIRCULATION PUMP TRIP SYSTEM RESPONSE TIME 1.12 The END-OF-CYCLE RECIRCULATION PUMP TRIP SYSTEM RESPONSE TIME shall be that time interval to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker from initial movement of the associated:

a. Turbine stop valves, and

b. Turbine control valves.

This total system response time consists of two components, the instrumen-tation response time and the breaker arc suppression time. These times may be measured by any series of sequential, overlapping or total steps such that the entire response time is measured.

1.13 (Deleted) 1.14 (Deleted)

FREQUENCY NOTATION 1.15 The FREQUENCY NOTATION specified for the performance of Surveillance Requirements shall correspond to the intervals defined in Table 1.1.

HIGH (POWER) TRIP SETPOINT CHTSP) l.15a The high power trip setpoint associated with the Rod Block Monitor (RBM) rod block trip setting applicable above 85% reactor thermal power.

IDENTIFIED LEAKAGE 1.16 IDENTIFIED LEAKAGE shall be:

a. Leakage into collection systems, such as pump seal or valve packing leaks, that is captured and conducted to a sump or collecting tank, or

b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of the leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE.

INSERVICE TESTING PROGRAM l.16a The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f).

INTERMEDIATE (POWER) TRIP SETPOINT (ITSP) l.16b The intermediate power trip setpoint associated with the Rod Block Monitor (RBM)I rod block trip setting applicable between 65% and 85% reactor thermal power.

ISOLATION SYSTEM RESPONSE TIME 1.17 The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation actuation setpoint at the channel sensor until the isolation valves travel to their required positions.

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.

LIMITING CONTROL ROD PATTERN 1.18 A LIMITING CONTROL ROD PATTERN shall be a pattern which results in the core being on a thermal hydraulic limit, i.e., operating on a limiting value for APLHGR, LHGR, OR MCPR.

LINEAR HEAT GENERATION RATE 1.19 LINEAR HEAT GENERATION RATE CLHGR) shall be the heat generation per unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length.

LIMERICK - UNIT 1 1-3 Amendment No. ee, 225

APPLICABILITY SURVEILLANCE REOUIREMENJS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation.

Failure to perform a Surveillance within the specified Surveillance time interval and allowed extension per Specification 4.0.2, shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance time interval with a maximum allowable extension not to exceed 25%

of the surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified Surveillance time interval and allowed extension per Specification 4.0.2, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Surveillance time interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

4.0.4 Entry into an OPERATIONAL CONDITION or other specified condition in the Applicability of a Limiting Condition for Operation shall only be made when the Limiting Condition for Operation's Surveillance Requirements have been met within their Surveillance time interval, except as provided in Specification 4.0.3. When a Limiting Condition for Operation is not met due to its Surveillance Requirements not having been met, entry into an OPERATIONAL CONDITION or other specified condition in the Applicability shall only be made in accordance with Specification 3.0.4.

This provision shall not prevent entry into 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.

4.0.5 Inservice Inspection and Inservice Testing Program The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f). The Inservice Inspection Program is the licensee program that fulfills the requirements of 10 CFR 50.SSa(g).

The provisions of SR 4.0.2 and SR 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific SR referencing usage of the program.

LIMERICK - UNIT 1 3/4 0-2 Amendment No. 1:3:,38, -ir5,~ 1 :l:69, -i94,225

APPLICABILITY SURVEILLANCE REQUIREMENTS (Continued)

LIMERICK - UNIT 1 3/4 0-3 Amendment No. l:l:,49, ~.3:79:, 194,225

CONTAINMENT SYSTEMS MSIV LEAKAGE ALTERNATE DRAIN PATHWAY LIMIJING CONDITION FOR OPERAJION 3.6.1.4 The MSIV Leakage Alternate Drain Pathway shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

With the MSIV Leakage Alternate Drain Pathway inoperable, restore the pathway to OPERABLE status within 30 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURYEILLANCE REQUIREMENTS 4.6.1.4 The MSIV Leakage Alternate Drain Pathway shall be demonstrated OPERABLE:

a. In accordance with Specification 4.0.5, by cycling each motor operated valve, required to be repositioned, through at least one complete cycle of full travel.

LIMERICK - UNIT 1 3/4 6-7 Amendment No. ~. 191,225

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. 188 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 (the licensee), dated July 26, 2016, 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 10 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 Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 188, 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 90 days.

FOR THE NUCLEAR REGULATORY COMMISSION

.------~\ /~

(__/~~,_

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: May 16, 2017

ATTACHMENT TO LICENSE AMENDMENT NO. 188 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 revised page.

The revised page is identified by amendment number and contains a marginal line indicating the area of change.

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

Remove Insert 1-3 1-3 3/4 0-2 3/4 0-2 3/4 0-3 3/4 0-3 3/4 6-7 3/4 6-7

(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 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. 188, 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. 188

DEFINITIONS END-OF-CYCLE RECIRCULATION PUMP TRIP SYSTEM RESPONSE TIME 1.12 The END-OF-CYCLE RECIRCULATION PUMP TRIP SYSTEM RESPONSE TIME shall be that time interval to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker from initial movement of the associated:

a. Turbine stop valves, and

b. Turbine control valves.

This total system response time consists of two components, the instrumen-tation response time and the breaker arc suppression time. These times may be measured by any series of sequential, overlapping or total steps such that the entire response time is measured.

1. 13 (De1eted) 1.14 (De 1eted)

FREQUENCY NOTATION 1.15 The FREQUENCY NOTATION specified for the performance of Surveillance Requirements shall correspond to the intervals defined in Table 1.1.

HIGH (POWER) TRIP SETPOINT CHTSP) l.lSa The high power trip setpoint associated with the Rod Block Monitor (RBM) rod block trip setting applicable above 85% reactor thermal power.

IDENTIFIED LEAKAGE 1.16 IDENTIFIED LEAKAGE shall be:

a. Leakage into collection systems, such as pump seal or valve packing leaks, that is captured and conducted to a sump or collecting tank, or

b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of the leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE.

INSERVICE TESTING PROGRAM l.16a The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.SSa(f).

INTERMEDIATE CPQWER) TRIP SETPOINT CITSP) 1.16b The intermediate power trip setpoint associated with the Rod Block Monitor (RBM) rod block trip setting applicable between 65% and 85% reactor thermal power.

ISOLATION SYSTEM RESPONSE TIME 1.17 The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation actuation setpoint at the channel sensor until the isolation valves travel to their required positions.

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.

LIMITING CONTROL ROD PATTERN 1.18 A LIMITING CONTROL ROD PATTERN shall be a pattern which results in the core being on a thermal hydraulic limit, i.e., operating on a limiting value for APLHGR, LHGR, or MCPR.

LINEAR HEAT GENERATION RATE 1.19 LINEAR HEAT GENERATION RATE (LHGR) shall be the heat generation per unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length.

LIMERICK - UNIT 2 1-3 Amendment No. 48,188

APPLICABILITY SURYEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance within the specified Surveillance time interval and allowed extension per Specification 4.0.2, shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance time interval with a maximum allowable extension not to exceed 25% of the surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified Surveillance time interval and allowed extension per Specification 4.0.2, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Surveillance time interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION requirements must be entered.

4.0.4 Entry into an OPERATIONAL CONDITION or other specified condition in the Applicability of a Limiting Condition for Operation shall only be made when the Limiting Condition for Operation's Surveillance Requirements have been met within their Surveillance time interval, except as provided in Specification 4.0.3. When a Limiting Condition for Operation is not met due to its Surveillance Requirements not having been met, entry into an OPERATIONAL CONDITION or other specified condition in the Applicability shall only be made in accordance with Specification 3.0.4.

This provision shall not prevent entry into 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.

4.0.5 Inservice Inspection and Inservice Testing Program The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.5Sa(f). The Inservice Inspection Program is the licensee program that fulfills the requirements of 10 CFR 50.55a(g).

The provisions of SR 4.0.2 and SR 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific SR referencing usage of the program.

LIMERICK - UNIT 2 3/4 0-2 Amendment No. 5, 89, 1:?4, 1-3-2, +/--5-5,188

APPLICABILITY SURVEILLANCE REQUIREMENTS CContinued2 LIMERICK - UNIT 2 3/4 0-3 Amendment No. +/-2-, 89, +/-3-3, 1-5-5, 188

CONTAINMENT' SYSTEMS MSIV LEAKAGE ALTERNATE DRAIN PATHWAY LIMITING CO~DITION FOR OPERAJIO~_

3.6.1.4 The MSIV Leakage Alternate Drain Pathway shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

With the MSIV Leakage Alternate Drain Pathway inoperable, restore the pathway to OPERABLE status within 30 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURYEILLANCE__REQUIREMENTS 4.6.1.4 The MSIV Leakage Alternate Drain Pathway shall be demonstrated OPERABLE:

a. In accordance with Specification 4.0.5, by cycling each motor operated valve, required to be repositioned, through at least one complete cycle of full travel.

LIMERICK - UNIT 2 3/4 6-7 Amendment No. 34, 53, 188

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 225 AND 188 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 July 26, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16210A227), Exelon Generation Company, LLC (the licensee) submitted a license amendment request for the Limerick Generating Station (LGS), Units 1 and 2.

The proposed amendments would modify Technical Specifications (TSs) consistent, in part, with Technical Specifications Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF-545, Revision 3, "TS lnservice Testing Program Removal & Clarify SR

[Surveillance Requirement] Usage Rule Application to Section 5.5 Testing," dated October 21, 2015 (ADAMS Accession No. ML15294A555). The licensee's proposed changes delete the inservice testing (IST) program requirements from LGS, Units 1 and 2, TS SR 4.0.5 (hereafter "TS 4.0.5"), and replace them with a note. The changes also add a new defined term, "INSERVICE TESTING PROGRAM," in Section 1 of the TSs, and the word "Specification" to the reference to 4.0.5 in TS SR 4.6.1.4.

The LGS TSs are based on the wording contained in the Standard Technical Specifications (STS) for General Electric boiling-water reactors (NUREG-0123), and the wording and format vary slightly from the U.S. Nuclear Regulatory Commission (NRC or the Commission) Improved Standard Technical Specifications for General Electric boiling-water reactor/4 plants (NUREG-1433), as shown in TSTF-545, Revision 3.

2.0 REGULATORY EVALUATION

2.1 Description of lnservice Testing Requirements and TSTF-545 An inservice test is a test to assess the operational readiness of a structure, system, or component after first electrical generation by nuclear heat. The American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) provides requirements for IST of certain components in light-water nuclear power plants. The ASME OM Code identifies the components subject to the testing (i.e., pumps, valves, pressure relief devices, and dynamic restraints), responsibilities, methods, intervals, parameters to be measured and evaluated, and criteria for evaluating results, corrective actions, personnel Enclosure 3

qualification, and recordkeeping. Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(f),

"lnservice testing requirements," requires that IST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda. The facility's TSs also prescribe IST requirements and frequencies for ASME Code Class 1, 2, and 3 components.

The regulation in 10 CFR 50.55a(f)(5)(ii) states, in part: "If a revised inservice test program for a facility conflicts with the technical specifications for the facility, the licensee must apply to the Commission for amendment of the technical specifications to conform the technical specifications to the revised program." TSTF-545, Revision 3, provides guidance to licensees on how to request license amendments that would eliminate conflicting requirements between 10 CFR 50.55a, "Codes and standards," and the TSs. TSTF-545, Revision 3, proposes elimination of the IST program from the Administrative Controls section of the TSs. The TSs contain surveillances that require testing or test intervals in accordance with the IST program.

The elimination of the IST program from the TSs could cause uncertainty regarding the correct application of these SRs. Therefore, TSTF 545, Revision 3, also proposes adding a new definition, "INSERVICE TESTING PROGRAM," to the TSs, which would be defined as "the licensee program that fulfills the requirements of 10 CFR 50.55a(f)." TSTF-545, Revision 3, proposes replacement of existing uses of the term, "lnservice Testing Program," with the defined term, as denoted by capitalized letters, throughout the TSs.

The NRC approved TSTF-545, Revision 3, by letter dated December 11, 2015 (ADAMS Package Accession No. ML15317A071), and published a notice of availability in the Federal Register on March 28, 2016 (81 FR 17208).

2.2 Proposed Technical Specifications Changes The licensee requested to delete TS 4.0.5 and replace it with a note. LGS, Units 1 and 2, TS 4.0.5 currently states:

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, & 3 components shall be applicable as follows:

a. lnservice inspection of ASME Code Class 1, 2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50, Section 50.55a. lnservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda as required by 10 CFR Part 50, Section 50.55a.

b. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection activities, and the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) and applicable Addenda for inservice testing activities, shall be applicable as follows in these Technical Specifications:

Required frequencies ASME Code and applicable Addenda for performing inservice terminology for inservice inspection and testing inspection and testing activities activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days

c. The provisions of Specification 4.0.2 are applicable to the above required frequencies for performing inservice inspection and testing activities. In addition, the provision of Specification 4.0.2 are applicable to other normal and accelerated frequencies specified as 2 years or less in the lnservice Testing Program for performing inservice testing activities.

d. Performance of the above inservice inspection and testing activities shall be in addition to other specified Surveillance Requirements.

e. Nothing in the ASME Code shall be construed to supersede the requirements of any Technical Specification.

f. The lnservice Inspection (ISi) Program for piping identified in NRC Generic Letter 88-01 shall be performed in accordance with the staff positions on schedule, methods and personnel, and sample expansion included in the Generic Letter, or in accordance with alternate measures approved by the NRC staff. Details for implementation of these requirements are included as augmented inspection requirements in the ISi Program.

The licensee proposes to replace the above IST requirements with a note stating:

lnservice Inspection and lnservice Testing Program The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f). The lnservice Inspection Program is the licensee program that fulfills the requirements of 10 CFR 50.55a(g).

The provisions of SR 4.0.2 and SR 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific SR referencing usage of the program.

The licensee requested to revise the Definitions section of TSs by adding Definition 1.16a, "INSERVICE TESTING PROGRAM," with the following definition: "The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f)."

The licensee also requested to add the word "Specification" to the reference to 4.0.5 in TS SR 4.6.1.4.

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

Technical Specifications The regulations in 10 CFR 50.36(c) require TSs to include the following categories: (1) safety limits, limiting safety systems settings, and control settings; (2) limiting conditions for operation; (3) SRs; (4) design features; (5) administrative controls; (6) decommissioning; (7) initial notification; and (8) written reports. The regulation in 10 CFR 50.36(c)(3) states: "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met."

The NRC staff's guidance for review of the TSs is in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor]

Edition," Chapter 16, "Technical Specifications," Revision 3, March 2010 (ADAMS Accession No. ML100351425). As part of the regulatory standardization effort described therein, the NRC staff has prepared Improved STS for each of the LWR nuclear steam supply systems and associated balance-of-plant equipment systems. The licensee's proposed amendments are based on TSTF-545, Revision 3, which is an NRG-approved change to the Improved STS. The NRC staff's review includes consideration of whether the proposed changes are consistent with TSTF-545, Revision 3. Special attention is given to TS provisions that depart from the Improved STS, as modified by NRG-approved TSTF Travelers, to determine whether proposed differences are justified by uniqueness in plant design or other considerations so that 10 CFR 50.36, "Technical specifications," is met. In addition, the guidance states that comparing the changes to previous STS can help clarify the intent of the TSs.

lnservice Testing Pursuant to 10 CFR 50.54, "Conditions of licenses," the applicable requirements of 10 CFR 50.55a are conditions of every nuclear power reactor operating license issued under 10 CFR Part 50. These requirements include IST of pumps and valves at nuclear power reactors in accordance with the ASME OM Code, as specified in 10 CFR 50.55a(f). The regulations in 10 CFR 50.55a(f) state, in part:

Systems and components of boiling and pressurized water-cooled nuclear power reactors must meet the requirements of the ASME BPV Code and ASME Code for Operation and Maintenance of Nuclear Power Plants as specified in this paragraph. Each operating license for a boiling or pressurized water-cooled nuclear facility is subject to the following conditions [referring to 10 CFR 50.55a(f)(1) through (f)(6)] ....

The ASME OM Code is a consensus standard that is incorporated by reference into 10 CFR 50.55a. During the incorporation process, the NRC staff reviewed the ASME OM Code requirements for technical sufficiency and found that the ASME OM Code IST program requirements were suitable for incorporation into the NRC's rules.

The regulation in 10 CFR 50.55(a)(f)(5)(ii) states, in part: "If a revised inservice test program for a facility conflicts with the technical specifications for the facility, the licensee must apply to the Commission for amendment of the technical specifications to conform the technical specifications to the revised program."

NUREG-1482, Revision 2, "Guidelines for lnservice Testing at Nuclear Power Plants: lnservice Testing of Pumps and Valves and lnservice Examination and Testing of Dynamic Restraints (Snubbers) at Nuclear Power Plants, Final Report," published October 2013 (ADAMS Accession No. ML13295A020), provides guidance for the IST of pumps and valves.

NUREG-0800, Section 3.9.6, "Functional Design, Qualification, and lnservice Testing Programs for Pumps, Valves, and Dynamic Restraints, Revision 3, March 2007 (ADAMS Accession No. ML070720041 ), provides guidance and acceptance criteria for the NRC staff review of the IST program for pumps and valves.

3.0 TECHNICAL EVALUATION

The NRC staff evaluated the licensee's application to determine if the proposed changes are consistent with the guidance, regulations, and licensing information discussed in Section 2.3 of this safety evaluation. In determining whether an amendment to a license will be issued, the Commission is guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. Among the considerations are whether the TSs, as amended, would 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 under 10 CFR 50.36(c)(3). In making its determination as to whether to amend the license, the NRC staff considered those regulatory requirements that are automatically conditions of the license through 10 CFR 50.54. Where the regulations already condition the license, there is no need for a duplicative requirement in the TSs; the regulations provide the necessary reasonable assurance of the health and safety of the public.

3.1 Deletion of the lnservice Testing Program from the Technical Specifications Consideration of TS 4.0.5.a LGS, Units 1 and 2, TS 4.0.5 specifies, in part, requirements for the plant's IST program.

TS 4.0.5.a requires that ASME Code Class 1, 2, and 3 pumps and valves be tested in accordance with the ASME OM Code and applicable addenda, as required by 10 CFR 50.55a.

Through 10 CFR 50.54, the applicable requirements of 10 CFR 50.55a are conditions of every nuclear power reactor operating license issued under 10 CFR Part 50. These requirements include 10 CFR 50.55a(f), which specifies the requirements for the IST of pumps and valves.

Therefore, requiring the licensee to have an IST program in TSs is duplicative of the license condition in 10 CFR 50.54. With the proposed TS changes, the licensee will still be required to maintain an IST program in accordance with the ASME OM Code, as specified in 10 CFR 50.55a(f). Thus, the NRC staff determined that deletion of TS 4.0.5.a is acceptable. For the reasons explained below, it is not necessary to have additional administrative controls in the TSs relating to the IST program to assure operation of the facility in a safe manner.

Consideration of TS 4. 0. 5. b The ASME OM Code requires testing to normally be performed within certain time periods.

TS 4.0.5.b sets IST frequencies more precisely than those specified in the ASME OM Code and

applicable addenda (e.g., "at least once per 31 days," contrasted with "monthly"). However, the NRC staff determined that the more precise IST frequencies are not necessary to assure operation of the facility in a safe manner. Therefore, the NRC staff determined that deletion of TS 4.0.5.b is acceptable.

Consideration of TS 4. 0. 5. c TS 4.0.5.c allows the licensee to extend, by up to 25 percent, the interval between IST activities, as required by TS 4.0.5.b and for other normal and accelerated frequencies specified as 2 years or less in the IST program. The NRC has not authorized the use of ASME Code Case OMN-20, "lnservice Test Frequency," or similar alternatives to the ASME OM Code for LGS, Units 1 and 2. Like TS 4.0.5.b, these NRG-authorized alternatives also permit the licensee to extend the IST intervals specified in the ASME OM Code by up to 25 percent.

The licensee proposed to add a note to replace the deleted requirements of TS 4.0.5. The acceptability of the proposed note is further evaluated in Section 3.2 of this safety evaluation.

The proposed note contains a statement affirming, in part, that: "The provisions of SR 4.0.2 and SR 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific SR referencing usage of the program." This statement adequately clarifies the applicability of SR 4.0.2 to IST associated with a TS SR The NRC staff determined that since LGS is not approved to use Code Case OMN-20 and the allowance of the provisions contained in SR 4.0.2 are still afforded by the new proposed note in SR 4.0.5, the deletion of TS 4.0.5.c is acceptable and the revised TS continues to assure operation of the facility in a safe manner .

Consideration of TS 4. 0. 5. d TS 4.0.5.d states that performance of the IST activities shall be in addition to other specified SRs. TS 4.0.5.d documents an already established requirement of ensuring the SRs contained in TSs are performed and met. Specifically, LGS, Units 1 and 2, SR 4.0.1, states:

Surveillance Requirements shall be met during the OPERATIONAL CONDITIONS or other specified conditions in the Applicability for individual Limiting Conditions for Operation, unless otherwise stated in the Surveillance Requirement. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance within the specified Surveillance time interval and allowed extension per Specification 4.0.2, shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

The NRC staff determined that TS 4.0.5.d is not necessary, since LGS, Units 1 and 2, SR 4.0.1, provides a redundant requirement. Therefore, the NRC staff determined that deletion of TS 4.0.5.d is acceptable, and the revised TS continues to assure operation of the facility in a safe manner.

Consideration of TS 4. 0. 5. e TS 4.0.5.e states that nothing in the ASME OM Code shall be construed to supersede the requirements of any TSs. However, the regulations in 10 CFR 50.55a(f)(5)(ii) address what to do if a revised IST program for a facility conflicts with the TSs for the facility. The regulations require the licensee to apply for an amendment to the TSs to conform the TSs to the revised program at least 6 months prior to the start of the period for which the provisions become applicable. Accordingly, there is no need for a TS stating how to address conflicts between the TSs and the IST program because the regulations specify how conflicts must be resolved.

Therefore, the NRC staff determined that deletion of TS 4.0.5.e is acceptable.

Consideration of TS 4. 0. 5. f The licensee proposes to delete TS 4.0.5.f, which requires that the ISi program for piping identified in NRC Generic Letter 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping," be performed in accordance with the staff positions on schedule, methods, personnel, and sample expansion included in the generic letter, or in accordance with alternate measures approved by the NRC staff. The NRC staff has verified that duplicative requirements are included and implemented in Section 2.2.1, "Augmented Inspection Requirements," in the third 10-year ISi program at LGS, Units 1 and 2. Thus, with the proposed TS changes, the licensee will still be required to maintain similar TS requirements in the licensee's ISi program.

Accordingly, the NRC staff finds that the proposed deletion of TS 4.0.5.f does not impact the licensee's implementation or performance of the TS-required inspection and is, therefore, acceptable.

Conclusion Regarding Deletion of TS 4. 0. 5 The NRC staff determined that the IST program requirements currently in TS 4.0.5 are not necessary to assure (1) operation of the facility in a safe manner, or (2) if 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. Based on this evaluation, the staff concludes that deletion of the IST program requirements from TS 4.0.5 is acceptable because the current requirements are not required by 10 CFR 50.36(c)(3).

3.2 Addition of Note to Replace TS 4.0.5 The licensee proposes to add a note as a replacement for the deleted IST requirements. The note will contain the definition of the IST program, the adequacy of which is evaluated in Section 3.3 of this safety evaluation. The note also contains a statement affirming that the provisions of SR 4.0.2 and SR 4.0.3 do not apply to the INSERVICE TESTING PROGRAM unless there is a specific TS SR referencing usage of the program.

The proposed statement permitting the provisions of SR 4.0.2 is evaluated in the subsection entitled "Consideration of TS 4.0.5.c" of Section 3.1 above.

The proposed statement permitting the provisions of SR 4.0.3 would allow the licensee to use SR 4.0.3 when it discovers that an SR associated with an inservice test was not performed within its specified frequency. SR 4.0.3 allows the licensee to delay declaring a limiting condition for operation not met in order to perform the missed surveillance. The use of SR 4.0.3 for inservice tests would be limited to those inservice tests required by an SR. In accordance with 10 CFR 50.55a, the licensee may also request relief from the ASME OM Code

requirements to address issues associated with a missed inservice test. The addition of the proposed statement allowing use of SR 4.0.3 clarifies current TS allowance. SR 4.0.3 continues to apply to those inservice tests required by SRs.

Based on the above, and the evaluations contained in subsection entitled "Consideration of TS 4.0.5.c" of Section 3.1 above, and Section 3.3 below, the NRC staff determined that the addition of the proposed note is acceptable.

3.3 Definition of "lnservice Testing Program" and Revisions to Surveillance Requirements The licensee proposes to revise the TS Definitions section to add Definition 1.16b, "INSERVICE TESTING PROGRAM," with the following definition: "The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f)." The proposed definition of the INSERVICE TESTING PROGRAM is consistent with the definition in TSTF-545, Revision 3. The definition is acceptable to the NRC staff because it correctly refers to the IST requirements in 10 CFR 50.55a(f).

3.4 Addition of "Specification" to SR 4.6.1.4 The licensee proposes to add the word "Specification" to the reference to 4.0.5 in SR 4.6.1.4.

Currently, SR 4.6.1.4a states: "In accordance with 4.0.5, by cycling each motor operated valve, required to be repositioned, through at least one complete cycle of full travel." The revised SR will now state: "In accordance with Specification 4.0.5, by cycling each motor operated valve, required to be repositioned, through at least one complete cycle of full travel."

The proposed change does not alter how the SR testing is performed. It clarifies number 4.0.5 as part of a TS reference. The staff determined that with the proposed changes, 10 CFR 50.36(c)(3) will continue to be met because the SR will continue to ensure 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.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments on April 10, 2017. 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 published in the Federal Register on October 25, 2016 (81 FR 73435) 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 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 J. Huang M. Farnan Date: May 16, 2017

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1AND2- ISSUANCE OF AMENDMENTS TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-545 (CAC NOS. MF8193 AND MF8194) DATED MAY 16, 2017 DISTRIBUTION:

Public RidsNrrPMLimerick Resource LPL 1 R/F CTilton, NRR RidsNrrLALRonewicz Resource RidsACRS_MailCTR Resource RidsRgn1 MailCenter Resource JHuang, NRR RidsNrrDorlLpl1 Resource RidsNrrDssEpnb Resource RidsNrrDssStsb Resource ADAMS A ccess1on N o.: ML17103A081 *b1y memoran dum **b1y e-ma1 OFFICE DORL/LPL 1/PM DORL/LPL 1/LA DSS/STSB/BC* DE/EPNB/BC**

NAME VSreenivas LRonewicz AKlein DAiiey DATE 04/26/2017 04/20/2017 03/30/2017 02/18/2017 OGC- NLO OFFICE (subject to comments DORL/LPL 1/BC DORL/LPL 1/PM in 5/12/17 e-mail)

NAME A Ghosh JDanna VSreenivas DATE 05/12/2017 05/16/2017 05/16/2017 OFFICIAL RECORD COPY