Text

Constellation Energy Generation - Application to Revise Technical Specifications to Adopt TSTF-597, Revision 0, Eliminate LCO 3.0.3 Mode 2 Requirement
	ML25031A384
Person / Time
Site:	Peach Bottom, Nine Mile Point, Limerick, Clinton, FitzPatrick, LaSalle
Issue date:	01/31/2025
From:	Steinman R; Constellation Energy Generation
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	RS-25-010
	Download: ML25031A384 (1)
	v • d • e

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office 10 CFR 50.90 RS-25-010 January 31, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRC Docket No. 50-410 Peach Bottom Atomic Power Station, Units 2, and 3 Subsequent Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

Application to Revise Technical Specifications to Adopt TSTF-597, Revision 0, "Eliminate LCO 3.0.3 Mode 2 Requirement"

Reference:

TSTF-597, Revision 0, "Eliminate LCO 3.0.3 Mode 2 Requirement," dated December 26, 2024 (ADAMS Accession No. ML24358A224)

January 31, 2025 U.S. Nuclear Regulatory Commission Page 2 In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Facility Operating License No. NPF-62 for the Clinton Power Station (CPS), Unit 1; No. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF); Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS), Units 1 and 2; Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2; No. NPF-69 for Nine Mile Point Nuclear Station, Unit 2 (NMP2);

and Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 respectively. Specifically, CEG requests adoption of referenced TSTF-597, Revision 0, "Eliminate LCO 3.0.3 Mode 2 Requirement," an approved change to the Standard Technical Specifications (STS), into each listed site's TS. TSTF-597 revises LCO 3.0.3 to eliminate the requirement to enter Mode 2.

provides a description and assessment of the proposed change. Attachment 2 provides the existing TS pages marked-up to show the proposed TS change. Attachment 3 provides the corresponding marked-up TS Bases pages and is provided for information only.

The proposed change has been reviewed by each listed site's Plant Operations Review Committee, respectively, in accordance with the requirements of the CEG Quality Assurance Program.

CEG requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed license amendment is requested within 6 months of the NRC acceptance review. Once approved, the amendment shall be implemented within 60 days.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), a copy of this application, with attachments, is being provided to the designated State Officials.

There are no regulatory commitments contained in this submittal. Should you have any questions concerning this submittal, please contact Mr. Nick Lien at (779) 231-6283.

I declare under penalty of perjury that the foregoing is true and correct. This statement was executed on the 31st day of January 2025.

Respectfully, Rebecca L. Steinman Sr Manager - Licensing Constellation Energy Generation, LLC

Steinman, Rebecca Lee Digitally signed by Steinman, Rebecca Lee Date: 2025.01.31 13:37:47

-06'00'

January 31, 2025 U.S. Nuclear Regulatory Commission Page 3 Attachments:

1. Evaluation of Proposed Changes

2. Mark-up of Technical Specifications Pages

3. Mark-up of Technical Specifications Bases Pages - For Information Only cc:

NRC Regional Administrator, Region I NRC Regional Administrator, Region III NRC Senior Resident Inspector, Clinton Power Station NRC Project Manager, Clinton Power Station NRC Senior Resident Inspector, James A. FitzPatrick Nuclear Power Plant NRC Project Manager, James A. FitzPatrick Nuclear Power Plant NRC Senior Resident Inspector, LaSalle County Station NRC Project Manager, Lasalle County Station NRC Senior Resident Inspector, Limerick Generating Station NRC Project Manager, Limerick Generating Station NRC Senior Resident Inspector, Nine Mile Point Nuclear Station NRC Project Manager, Nine Mile Point Nuclear Station NRC Senior Resident Inspector, Peach Bottom Atomic Power Station NRC Project Manager, Peach Bottom Atomic Power Station Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection A. L. Petersen, NYSERDA Bridget Frymire, NYSPSC Andrew Kauk, NYSPSC

ATTACHMENT 1 Evaluation of Proposed Changes

Subject:

Application to Revise Technical Specifications to Adopt TSTF-597, Revision 0, "Eliminate LCO 3.0.3 Mode 2 Requirement" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Applicability 2.2 Variations 2.3 Detailed Description of Change

3.0 TECHNICAL EVALUATION

3.1.

BWR LCO 3.0.3 Shutdown Completion Times are Unique in the STS 3.2 Requiring Entry into Mode 2 Does Not Improve Plant Safety 3.3 BWR LCO 3.0.3 Requirement to Enter Mode 2 is Inconsistent with Typical Plant Operation

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements / Criteria 4.2 No Significant Hazards Consideration 4.3 Conclusion

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

ATTACHMENT 1 Evaluation of Proposed Changes Page 2 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Facility Operating License No. NPF-62 for the Clinton Power Station (CPS), Unit 1; No. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF); Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS), Units 1 and 2; Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2; No. NPF-69 for Nine Mile Point Nuclear Station, Unit 2 (NMP2);

and Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 respectively. Specifically, CEG requests adoption of TSTF-597, Revision 0, "Eliminate LCO 3.0.3 Mode 2 Requirement" (Reference 6.1), an approved change to the Standard Technical Specifications (STS), into each listed site's TS. TSTF-597 revises LCO 3.0.3 to eliminate the requirement to enter Mode 2.

2.0 DETAILED DESCRIPTION 2.1 Applicability CEG has reviewed the safety evaluation for TSTF-597 provided to the Technical Specifications Task Force in a letter dated December 26, 2024. This review included the NRC staffs evaluation, as well as the information provided in TSTF-597. CEG has concluded that the justifications presented in TSTF-597 and the safety evaluation prepared by the NRC staff are applicable to CPS, Unit 1; JAF; LSCS, Units 1 and 2; LGS, Units 1 and 2; NMP2; and PBAPS, Units 2 and 3 and justify this amendment for the incorporation of the changes to the respective plants TS.

2.2 Variations CEG is proposing the following variations from the TS changes described in TSTF-597 or the applicable parts of the NRC staffs safety evaluation:

The PBAPS TS permit a longer Completion Time to enter Mode 2 than the 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months in the STS.

This change was approved by the NRC in a letter dated May 10, 2006, Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendments RE: Incorporation of Previously NRC-Approved Generic Technical Specification Changes, (ML061070292, Reference 6.2). The different Completion Time does not affect the applicability of the proposed change to the PBAPS TS.

The LGS TS have not been updated to the Improved Technical Specifications (ITS) and currently reflect language that varies from NUREG-1433. Specifically, the LGS TS 3.0.3 time to the next mode change is referenced from the previous mode change as opposed to the time since LCO entry. This is an administrative variation only as the current LGS allowable time to Hot Shutdown, (13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months from LCO Entry) and Cold Shutdown (37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months from LCO Entry) is consistent with this Traveler. The revised mark-up is intended to make the wordings for 3.0.3 more closely match the ITS format.

ATTACHMENT 1 Evaluation of Proposed Changes Page 3 The NUREG-1433 TSs discussed in Section 3.1 of this Traveler, which require entry into Mode 2, are:

x 3.3.1.1, Reactor Protection System (RPS) Instrumentation x

3.3.4.1, ATWS RPT x

3.3.6.1, Primary Containment Isolation Function 1.b, Main Steal Line Pressure - Low.

The corresponding LGS trip functions are stated in LGS TS 3.3.1, RPS Instrumentation, 3.3.2, Isolation Instrumentation and 3.3.4.1, ATWS RPT.

In addition to RPS, ATWS RPT and Main Steam Line Pressure - Low, three (3) other LGS functions for TS 3.3.2 direct entry into Startup (MODE 2) and are all applicable in Modes 1, 2, and 3:

x Reactor Vessel Water Level Low/Low-Level 1/Low-Level 2 (LGS Function 1.a.1 and 1.a.2) x Condenser Vacuum - Low (LGS Function 1.e) x Outboard MSIV Room Temperature - High (LGS Function 1.f)

These functions also require isolating the associated Main Steam line within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The corresponding NUREG-1433 requirement allows up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to isolate OR be in MODE 3 (Hot Shutdown). These functions are more conservative than the NUREG-1433 required action, for the associated functions.

Additionally, LGS TS 3.3.9, Feedwater/Main Turbine Trip Actuation Instrumentation (applicable when Thermal Power 25%), and LGS TS 3.10.5, Oxygen Concentration (applicable in Mode 1), direct entry into Mode 2. The STS equivalent of LGS TS 3.3.9 is TS 3.3.2.2, Feedwater and Main Turbine High Water Level Trip Instrumentation which is also only applicable in Mode 1 when Core Thermal Power is 25%. LGS TS 3.10.5 has no STS equivalent but is only allowed during the performance of the Startup Test Program to allow suspension of LGS TS 3.6.6.3, Drywell and Suppression Chamber Oxygen Concentration so that access can be provided to the primary containment during the initial startup and testing phase of operation. These functions are not being changed nor does the requirement to be in Startup in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months impact the justification of provided in this Traveler.

The above variations regarding which other TS require Mode 2 entry does not affect the applicability of the proposed change to the LSG TS.

2.3 Detailed Description of Change TSTF-597 revises LCO 3.0.3 to eliminate the requirement to enter Mode 2.

contains a marked-up version of the TS for each site included in this LAR showing the proposed change. Attachment 3 provides the marked-up TS Bases pages for each site.

Supporting changes to the TS Bases will be made in accordance with each sites respective TS Bases Control Program. The TS Bases mark-up pages are being submitted for information only.

ATTACHMENT 1 Evaluation of Proposed Changes Page 4

3.0 TECHNICAL EVALUATION

As described in TSTF-597, Revision 0, the proposed change to eliminate the LCO 3.0.3 requirement to enter Mode 2 is justified because:

The LCO 3.0.3 requirement to enter Mode 2 is unique in the BWR STS and is not consistent with the safety significance of the condition.

Requiring entry into Mode 2 does not improve plant safety.

The BWR LCO 3.0.3 requirement to enter Mode 2 is inconsistent with typical plant operation.

3.1. BWR LCO 3.0.3 Shutdown Completion Times are Unique in the STS The typical Completion Times provided to shut down the plant in the current BWR STS are shown in Section 1.3, "Completion Times," Example 1.3-1:

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours These Completion Times have been the typical shutdown times since the original BWR STS were issued in 1976.

All other BWR STS require being in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and if applicable, being in Mode 4 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , including safety significant conditions in which an LCO or associated Actions are not met, such as:

Violation of shutdown margin,

Multiple inoperable control rods,

No recirculation loops in operation,

Inoperable Safety/Relief Valves,

Reactor Coolant System leakage greater than the limit,

Violation of the RCS pressure and temperature limits,

Multiple inoperable Emergency Core Cooling System (ECCS) components,

Inoperable primary containment, and

Inoperable AC and DC power sources.

ATTACHMENT 1 Evaluation of Proposed Changes Page 5 The only BWR STS Actions that require being in Mode 2 are for inoperable Reactor Protection System instrumentation functions that are only applicable in Mode 1, ATWS-RPT Instrumentation and Main Steam Line Pressure - Low Instrumentation which are only applicable in Mode 1, and LCO 3.0.3 that is applicable in Modes 1, 2, 3. The BWR LCO 3.0.3 requirement to be in Mode 2 in 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months is inconsistent compared to other Actions in the STS that represent significant degradations in plant safety.

3.2. Requiring Entry into Mode 2 Does Not Improve Plant Safety LCO 3.0.3 Bases state that the purpose of LCO 3.0.3 is to delineate the time limits for placing the unit in a safe Mode or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its Actions. However, a requirement to enter Mode 2, in which the reactor is still critical but at low power, does not place the unit in a safe Mode in which the LCO and its Actions are not applicable. In fact, the plant is less stable at low power than at full power.

It is notable that LCO 3.0.3 in the PWR STS does not require entering Mode 2 (reactor critical at low power, similar to BWR STS Mode 2). The PWR STS LCO 3.0.3 requires being in Mode 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . PWR plants can enter Mode 3 from Mode 1 during a controlled shutdown faster than equivalent BWR plants for several reasons. For example, PWR control rods are arranged in groups and the groups can be quickly driven into the reactor following a hardware-enforced sequence, while BWR control rods must be manually inserted individually in accordance with a procedure following an approved rod pattern. In addition, field manipulation of components, such as feedwater heaters, may take longer at BWRs due to the need for radiation protection controls on potentially contaminated areas.

3.3. BWR LCO 3.0.3 Requirement to Enter Mode 2 is Inconsistent with Typical Plant Operation During a shutdown, the usual BWR operating practice is to lower power and then place the Mode Switch in "Shutdown," initiating a reactor scram. When the Mode Switch is placed in "Shutdown," the unit enters Mode 3 from Mode 1, without entering Mode 2. In this situation, licensees have interpreted LCO 3.0.3 as requiring being in Mode 3 in 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months instead of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months as stated in LCO 3.0.3. This places unnecessary time constraints on plant operators.

There are no other BWR STS Actions that require being in Mode 3 in less than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

In some cases, licensees may manually insert the control rods to the fully inserted position, known as "soft shutdown." At low power, the Reactor Mode Switch is placed in "Startup,"

entering Mode 2. After the control rods are fully inserted, the Reactor Mode Switch is temporarily bypassed and placed in "Shutdown," to avoid a hydraulic "slamming" effect on the already inserted rods. This results in entry into Mode 3. Even in these nontypical shutdowns, the requirement to enter Mode 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months is consistent with the other shutdown requirements in the STS and does not justify imposing a 7-hour requirement to enter Mode 2.

In summary, elimination of the BWR LCO 3.0.3 requirement to enter Mode 2 is justified because it is unique in the BWR STS and not warranted by the safety significance of the condition, the requirement to enter Mode 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months does not improve plant safety, and the requirement to enter Mode 2 is inconsistent with typical plant operation

ATTACHMENT 1 Evaluation of Proposed Changes Page 6

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements / Criteria 10 CFR 50.36, Technical Specifications, paragraph (c)(2), Limiting Conditions for Operation.

This regulation states, "When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." LCO 3.0.3 satisfies this regulation by providing a requirement to shut down the reactor if an LCO is not met and the TS does not provide any other remedial action.

CEG has determined that the proposed change of removing the Mode 2 requirement is consistent with the regulatory requirements and criteria described above.

4.2 No Significant Hazards Consideration Overview In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Facility Operating License No. NPF-62 for the Clinton Power Station (CPS), Unit 1; No. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF); Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS), Units 1 and 2; Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2; No. NPF-69 for Nine Mile Point Nuclear Station, Unit 2 (NMP2);

and Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 respectively. Specifically, CEG requests adoption of referenced TSTF 597, Revision 0, "Eliminate LCO 3.0.3 Mode 2 Requirement," an approved change to the Standard Technical Specifications (STS), into each listed site's TS. TSTF-597 revises LCO 3.0.3 to eliminate the requirement to enter Mode 2.

CEG has evaluated the proposed change against the criteria of 10 CFR 50.92(c) to determine if the proposed changes result in any significant hazards. The following is the evaluation of each of the 10 CFR 50.92(c) criteria:

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode 2. The time required to shut down the plant after entering LCO 3.0.3 is not an initiator of any accident previously evaluated. Under the proposed change, the TS continue to require the plant to shut down and enter Mode 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for LGS). The consequences of any accident previously evaluated during the revised LCO 3.0.3 shutdown requirements are no different than the consequences of the same accident during the existing times.

ATTACHMENT 1 Evaluation of Proposed Changes Page 7 Therefore, the proposed change does not significantly increase the probability of an accident previously evaluated.

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode 2. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the current plant operating practice for all other TS required shutdowns.

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

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode 2. The proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analysis.

As such, there are no changes being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, CEG concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Conclusion Based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

ATTACHMENT 1 Evaluation of Proposed Changes Page 8

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 TSTF-597, Revision 0, "Eliminate LCO 3.0.3 Mode 2 Requirement," dated December 26, 2024 (ADAMS Accession No. ML24358A224) 6.2 NRC Letter, Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendments RE: Incorporation of Previously NRC-Approved Generic Technical Specification Changes, dated May 10, 2006 (ADAMS Accession No. ML061070292)

ATTACHMENT 1 Evaluation of Proposed Changes ATTACHMENT 2a CLINTON POWER STATION UNIT 1 Docket No. 50-461 Facility Operating License No. NPF-62 MARK-UP OF TECHNICAL SPECIFICATIONS PAGES

ATTACHMENT 2a CLINTON POWER STATION UNIT 1 Docket No. 50-461 Facility Operating License No. NPF-62 MARK-UP OF TECHNICAL SPECIFICATIONS PAGES

LCO Applicability 3.0 CLINTON 3.0-1 Amendment No. 233220 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b. MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c. MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; (continued) a.

b.

ATTACHMENT 2b JAMES A. FITZPATRICK NUCLEAR POWER STATION Docket No. 50-333 Renewed Facility Operating License No. DPR-59 MARK-UP OF TECHNICAL SPECIFICATIONS PAGES

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY JAFNPP 3.0-1 Amendment 337 LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the plant shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the plant, as applicable, in:

a.

MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ; b.

MODE 3 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and c.

MODE 4 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; (continued) a.

b.

ATTACHMENT 2c LASALLE COUNTY STATION UNITS 1 AND 2 Docket Nos. 50-373 and 50-374 Facility Operating License Nos. NPF-11 and NPF-18 MARK-UP OF TECHNICAL SPECIFICATIONS PAGES

LCO Applicability 3.0 LaSalle 1 and 2 3.0-1 Amendment No. 245/231 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.10.