JAFP-22-0008, Response to Request for Supplemental Information by the Office of Nuclear Reactor Regulation to Support Review of a License Amendment Request to Eliminate Selected Response Time Testing for Reactor Protection System and Primary

Response to Request for Supplemental Information by the Office of Nuclear Reactor Regulation to Support Review of a License Amendment Request to Eliminate Selected Response Time Testing for Reactor Protection System and Primary

ML22014A015
Person / Time
Site:	FitzPatrick
Issue date:	01/14/2022
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-22-0008
Download: ML22014A015 (24)

Text

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 10 CFR 50.91(a)(5)

JAFP-22-0008 January 14, 2022 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 Subkect: Response to Request for Supplemental Information by the Office of Nuclear Reactor Regulation to support Review of a License Amendment Request to Eliminate Selected Response Time Testing for Reactor Protection System and Primary Containment Isolation Instrumentation

Reference:

1. Letter from D. Gudger (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "License Amendment Request -

Propose Change to Eliminate Selected Response Time Testing for Reactor Protection System and Primary Containment Isolation Instrumentation (ML21291A110) dated October 18, 2021 By letter dated October 18, 2021, (Reference 1) Exelon Generation Company, LLC (Exelon) requested a change to the James A. FitzPatrick (JAF) Technical Specifications (TS) in accordance with 10 CFR 50.90. The proposed amendment request would eliminate selected Response Time Testing for Reactor Protection System and Primary Containment Isolation instrumentation.

Through telephone conversations with J. Poole, NRC Project Manager, and NRC staff between November 17, 2021 and November 19, 2021, the NRC communicated areas where additional information was necessary to validate the applicability of the technical justification provided in Reference 1.

The Attachment to this letter and the associated Enclosure contain the additional information necessary to validate the applicability of the technical justification. The information provided in this supplement is a more detailed description of the nomenclature used for the relays which are impacted by the request to eliminate selected Response Time Testing. Additionally, transposition errors from other documents into Reference 1 are being corrected to eliminate further confusion. These corrections are reflected in the Enclosure to this supplement. This information is not technical in nature.

Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference 1.

Response to Request for Supplemental Information by the Office of Nuclear Reactor Regulation to support Review of a License Amendment Request to Eliminate Selected Response Time Testing for Reactor Protection System and Primary Containment Isolation Instrumentation January 14, 2022 Page 2 The information attached to this letter does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration.

Furthermore, the information attached to this letter does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no commitments contained in this response.

If you should have any questions regarding this submittal, please contact Christian Williams at 610-765-5729.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 14th day of January 2022.

Respectfully, David T. Gudger Senior Manager, Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

SUPPLEMENTAL INFORMATION NEEDED J. A. FITZPATRICK LICENSE AMENDMENT REQUEST TO ELIMINATE SELECTED RESPONSE TIME TESTING FOR REACTOR PROTECTION SYSTEM AND PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION

Enclosure:

Revision 1 to Reference 1

Enclosure:

Description and Assessment cc: Regional Administrator - NRC Region I w/ attachments NRC Senior Resident Inspector - JAF NRC Project Manager, NRR - JAF A. L. Peterson, NYSERDA

ATTACHMENT SUPPLEMENTAL INFORMATION NEEDED J. A. FITZPATRICK LICENSE AMENDMENT REQUEST TO ELIMINATE SELECTED RESPONSE TIME TESTING FOR REACTOR PROTECTION SYSTEM AND PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION Page 1 of 2 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 By letter dated October 18, 2021, (Reference 1) Exelon Generation Company, LLC (Exelon) requested a change to the James A. FitzPatrick (JAF) Technical Specifications (TS) in accordance with 10 CFR 50.90. The proposed amendment request would eliminate selected Response Time Testing for Reactor Protection System and Primary Containment Isolation instrumentation.

Revised Instrument Model Names:

The technical justification for the elimination of selected Response Time Testing provided in Reference 1 is based on a BWR Owners Group Licensing Topical report, NEDO-33291-A Supplement 1, which is listed as Reference 3 in the Exelon request.

The applicability of the NEDO document is limited to the specific instrument types listed in the NEDO document. The Enclosure to Exelons submittal, Reference 1, listed the name and type of some of the relays, but in some cases, the relay type was not specific enough to confirm the applicability of the NEDO document. Specifically, Tables 3.2.1-1, 3.2.2.-1, 3.2.3-1, 3.2.4-1 and 3.2.5-1 each list the equipment and models for the instrumentation being tested. The model description for both the Logic Relays and Output Relays do not specifically identify the models installed in the system, but rather include the generic names HFA (for logic relays and some output relays) or RPS SCRAM Contactor (for the remaining output relays).

The affected tables have been updated and are included in a revision to Enclosure 1 of the original submittal. Enclosure 1 of this supplement should replace the original in its entirety.

Correction of Transposition Errors:

In the original submittal, Exelon made the following statement in five (5) places of the original Enclosure; These components arranged as shown on the loop drawings and schematics listed in Section 4 (or 5) match the Loop Type H (or E) as described in Section 6.2 of NEDO-32291-A.

ATTACHMENT SUPPLEMENTAL INFORMATION NEEDED J. A. FITZPATRICK LICENSE AMENDMENT REQUEST TO ELIMINATE SELECTED RESPONSE TIME TESTING FOR REACTOR PROTECTION SYSTEM AND PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION Page 2 of 2 This reference to Section 4 or 5 is a carryover reference to Section 4 or 5 of documents that are not part of the submittal. The referenced Sections list plant drawings which demonstrate that the component arrangement is the same as the applicable type (H or E) described in NEDO-32291-A Supplement 1. These drawings have been added to the list of Enclosure References as references 8 thru 25. The associated statements have been revised to refer directly to the Enclosure References. As discussed above, the References section of Enclosure 1 included with this supplement should replace the Reference Section of the original Enclosure 1.

ENCLOSURE Revision 1 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 Evaluation of Proposed Changes

Subject:

Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

3.1 Background

3.2 Justification

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedence 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 2 of 20 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Exelon Generation Company, LLC (Exelon), requests the following amendment to Appendix A, Technical Specifications (TS), of Renewed Facility Operating License No.

DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF).

The proposed changes would modify the TS to eliminate the response time testing (RTT) requirements for TS Section 3.3.1.1, Reactor Protection System (RPS) Instrumentation, Reactor Pressure - High function, Reactor Vessel Water Level - Low (Level 3) function and TS Section 3.3.6.1, "Primary Containment Isolation Instrumentation" Reactor Vessel Water Level - Low Low Low (Level 1) function, Main Steam Line Pressure - Low function and Main Steam Line Flow - High function. The proposed changes are consistent with the BWR Owners Group Licensing Topical report (Reference 5) as approved by the Nuclear Regulatory Commission (NRC) (Reference 6).

Elimination of the response time testing requirements will result in significant improvement in plant safety by: (1) minimizing the time when safety systems are out of service or otherwise incapable of responding to a degraded plant condition; (2) reducing the potential for inadvertent essential safety function (ESF) actuations; (3) reducing the complexity of refuel outages and thus reducing shutdown risk; (4) reducing personnel radiation exposure; and, (5) allowing critical personnel to be used for more significant tasks.

2.0 DETAILED DESCRIPTION 2.1 TS Section 3.3.1.1, Table 3.3.1.1-1 Function 3, Reactor Pressure - High specifies SR 3.3.1.1.15 as applicable to this function. Function 3 is being revised to delete the applicability of SR 3.3.1.1.15.

2.2 TS Section 3.3.1.1, Table 3.3.1.1-1 Function 4, Reactor Vessel Water Level - Low (Level 3) specifies SR 3.3.1.1.15 as applicable to this function. Function 4 is being revised to delete the applicability of SR 3.3.1.1.15.

2.3 TS Section 3.3.6.1, Table 3.3.6.1-1 Function 1.a, "Reactor Vessel Water Level - Low Low Low, (Level 1)" specifies SR 3.3.6.1.8 as applicable to this function. Function 1.a is being revised to delete the applicability of SR 3.3.6.1.8.

2.4 TS Section 3.3.6.1, Table 3.3.6.1-1 Function 1.b, "Main Steam Line Pressure - Low," specifies SR 3.3.6.1.8 as applicable to this function. Function 1.b is being revised to delete the applicability of SR 3.3.6.1.8.

2.5 TS Section 3.3.6.1, Table 3.3.6.1-1 Function 1.c, "Main Steam Line Flow - High," specifies SR 3.3.6.1.8 as applicable to this function. Function 1.b is being revised to delete the applicability of SR 3.3.6.1.8.

2.6 Surveillance Requirement (SR) 3.3.6.1.8 is deleted in its entirety as the above referenced functions are the only Primary Containment Isolation Instrumentation functions to which SR 3.3.6.1.8 apply.

In addition, the TS Bases will be revised to reflect the above proposed changes.

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 3 of 20

3.0 TECHNICAL EVALUATION

3.1

Background:

In January 1994, the Boiling Water Reactor Owners' Group {BWROG) issued Licensing Topical Report (LTR) NEDO-32291 (Reference 3). In this LTR. The BWROG proposed eliminating the requirements for performance of Response Time Testing (RTT) of selected instrumentation in the RPS, Emergency Core Cooling System (ECCS), and Isolation Actuation Signal (IAS). The NRC approved the LTR in an SER dated December 28, 1994 (Reference 4). Reference 3 established a generic basis for elimination of selected RTT requirements for instrument loops that had good performance histories and longer response time requirements. The result of this effort was a significant reduction of testing which was shown by the study to be unnecessary.

By letter dated May 30, 1996, JAF (then part of the Power Authority of the State of New York (PASNY))

proposed an amendment to its TS to eliminate selected response time testing (RTT) requirements for certain sensors and specified loop instrumentation (Reference 1). The proposed changes were supported by analyses performed by the Boiling Water Reactor Owners Group (BWROG) Topical Report. This request was approved by the Nuclear Regulatory Commission (NRC) on October 28, 1996 (Reference 2).

The BWROG subsequently issued Supplement 1 to Reference 3 on November 4, 1997 (Reference 5). The LTR supplement documents the results of the second phase of the BWROG Response Time Testing Committee's study to identify ways to further eliminate RTT requirements. With only a few exceptions, the study results documented in Reference 5 cover all RPS and IAS instrumentation loops with response time requirements in the intermediate response time range (i.e., 300 to 5000 msec) that were not considered in the first phase of the study documented in Reference 3. This generic LTR Supplement documented an analysis to extend the conclusions of the original study to cover logic components in selected instrumentation loops to demonstrate that elimination of the RTT requirements for the logic portions of those loops is of no safety significance. In Reference 6, the NRC documented their review of Reference 5 and the determination that the LTR Supplement provided an acceptable basis for eliminating selected RTT from TS for the instruments/components identified in the supplement.

3.2 Justification Consistent with Reference 3, the supplement to NEDO-32291-A (Reference 1) utilized the requirements of Institute of Electrical and Electronics Engineers (IEEE) Standard 338-1977, "Criteria for Periodic Testing of Nuclear Power Generating Station Safety Systems," as endorsed by NRC Regulatory Guide 1.118, "Periodic Testing of Electric Power and Protection Systems," which states the following:

"Response time testing of all safety-related equipment, per se, is not required if, in lieu of response time testing, the response time of the safety equipment is verified by functional testing, calibration checks or other tests, or both. This is acceptable if it can be demonstrated that changes in response time beyond acceptable limits are accompanied by changes in performance characteristics which are detectable during routine periodic tests."

The analysis contained in Reference 3 provides the basis for eliminating selected response time testing requirements. The analysis was performed for BWRs, and its applicability to JAF has been verified with regards to the proposed TS changes. JAF participated in the development of Reference 3 as documented in Appendix A of the NEDO document.

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 4 of 20 The BWROG analysis includes the identification of potential failure modes of components in the affected instrumentation loops that could potentially impact the instrument loop response time. In addition, plant operating experiences were reviewed to identify response time failures and how they were detected. The failure modes identified were evaluated to determine if the effect on response time would be detected by other testing requirements contained in the TS.

The results of the BWROG analysis demonstrate that any credible failure of the instrument loop components would either be bounded by a bounding response time (BRT) or would be detected by other TS testing requirements, such as a channel calibration, channel check, channel functional test, or logic system functional test. These other testing requirements are sufficient to identify failure modes or degradations in instrument response times and assure operation of the analyzed instrument loops are within acceptance limits. Furthermore, the BWROG has described various defense in depth issues (Reference 1) which clearly demonstrate that from a realistic basis, there is no safety significance even if instrumentation loop response times are significantly longer than the loop BRTs. Therefore, potential errors in the conclusions of the analysis and BRTs resulting from unanticipated failure modes of components do not affect the overall conclusion that elimination of the identified response time testing requirements has no substantial detrimental impact on plant safety.

A review of utility-supplied information for the loops included in the Reference 1 study was performed to identify the individual components comprising each of the instrument loops. Components with sufficiently similar design and construction features were grouped together into a component set for which a common Failure Modes and Effects Analysis (FMEA) was performed.

The BWROG utilized the results of the FMEAs, in conjunction with industry failure experience and component specifications, requirements, and performance test results, to establish a BRT. The BRT is the maximum response time expected for any component in the set that could result from credible undetected" component failures or degradation. Undetected component failures and degradations as used in Reference 1 are failures and degradations that are not expected to be detected either by immediate trip or by periodic surveillance actions other than response time testing. Response time increases up to the BRT may go undetected, but it is expected that any failure or degradation that results in a response time larger than the BRT will be detected by one or more surveillance actions other than response time testing. The BRT is established based on the assumption that specific RTT is not performed for the loop or component.

The BRT for each evaluated channel is determined by the summation of the individual component responses in the trip system actuation logic. In accordance with Reference 1 Section 8.5.1, the limiting BRT for the sensors is derived from the current RTT acceptance criteria. This value plus the sum of the channel relay BRTs is then compared to the current RTT limit required by the applicable RTT surveillance procedure.

JAF analyzed the functions stated below to confirm the applicability of NEDO-32291-A Supplement 1.

The functions/loops analyzed are as a follow:

• Reactor Pressure - High

• Reactor Vessel Water Level Low - Level 3

• Reactor Vessel Water Level Low Low Low - Level 1

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 5 of 20

• Main Steam Line Pressure - Low

• Main Steam Line Flow - High The following equipment requirements are applicable to all five (5) sections below.

Equipment Requirements NEDO-32291-A Supplement 1 lists the following requirements for the usage of the Bounding Response Time data for removal of the RTT from the Technical Specifications and Technical Specification Bases:

Rosemount 510DU and 710DU Trip Units must meet the following requirements:

• The trip units are procured by the utility as nuclear safety related or dedicated for nuclear safety related application under a utility dedication program.

Agastat EGPB relays must meet the following requirements:

• Prior to installation or after any maintenance or repair of the relays, the normally open contacts of the relay are confirmed to open in 70 milliseconds or less after power is removed from the coil.

• The relays are within their qualified life.

• The relays are procured by the utility as nuclear Safety Related or dedicated for nuclear Safety Related application under a utility dedication program.

GE HFA Relays must meet the following requirements

• The HFA manufacturers instructions are followed for setup and adjustment of the relay prior to the initial operation and after any repair or maintenance

• Prior to installation or after any maintenance or repair of the relays, the normally open contacts of the relays are confirmed to open in 20 milliseconds or less after power is removed from the coil.

• The relays are procured by the utility as nuclear Safety Related or dedicated for nuclear Safety Related application under a utility dedication program.

For SCRAM Contactors:

• The plant performs the APRM upscale SCRAM trip RTT with a loop acceptance criterion of 90 milliseconds maximum AND the APRM RTT includes the APRM electronics and at least one interposing relay, not shared by the other loops, between the APRM output and the RPS SCRAM contactor.

OR

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 6 of 20

• If the APRM RTT is completed in phases, the maximum undetected response time of the SCRAM contactors is 45 milliseconds, provided the acceptance criteria is 50 milliseconds maximum for that phase that includes the SCRAM contactor and at least one interposing relay not shared by the other loops.

3.2.1 REACTOR PRESSURE - HIGH The Reactor Pressure High sensors provide input to the RPS Scram Contactors when the pressure in the reactor rises above the determined setpoint. Equipment in the Reactor Pressure loops are listed in Table 3.2.1-1 below.

Revised Table 3.2.1-1: Reactor Pressure Loop Equipment and Models Sensor MTU TU Output Relay Logic Relay Output Relay 023PT55A 023MTU255A 05AK101A 05AK5A 05AK14A/E (Rosemount 710DU) (Agastat EGPB) (12HFA151A9) (RPS SCRAM Contactor GE CR105) 023PT55B 023MTU255B 05AK101B 05AK5B 05AK14B/F (Rosemount 710DU) (Agastat EGPB) (12HFA151A9) (RPS SCRAM Contactor GE CR105) 023PT55C 023MTU255C 05AK101C 05AK5C 05AK14C/G (Rosemount 710DU) (Agastat EGPB) (15HFA151A9) (RPS SCRAM Contactor GE CR105) 023PT55D 023MTU255D 05AK101D 05AK5D 05AK14D/H (Rosemount 710DU) (Agastat EGPB) (15HFA151A9) (RPS SCRAM Contactor GE CR105)

The components in these loops have been analyzed in NEDO-32291-A Supplement 1. See Section 6.1 of NEDO-32291-A Supplement 1 for details.

These components arranged as shown on the loop drawings and schematics listed in References 8 thru 15 match the Loop Type H as described in Section 6.2 of NEDO-32291-A.

Since the equipment installed in the plant matches the NEDO analyzed configuration, the plant procedures may be compared to the NEDO procedures to determine if they can be applied directly, or if modifications are required to implement the results of the report.

Bounding Response Time The Bounding Response Time (BRT) for a component is the maximum response time that could result from credible, undetected, component failures or degradation. Per NEDO-32291-A Supplement 1, these failures or degradation are not expected to be detectable by any actions other than period Response Time Testing. Failures that result in a response time higher than the BRT are considered detectable by periodic surveillance other than the RTT. The BRT for each component type has been determined in NEDO-32291-A Supplement 1 via FMEA, component specifications, and industry experience. In order to use the determined BRTs, certain procedural requirements must be met. See Section 3.2 for Equipment Requirements.

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 7 of 20 Table 3.2.1-2: Selected Equipment BRT from NEDO-32291-A, Supplement 1 Component Set Abbreviation Bounding Response Time Agastat Relays Agastat 140 milliseconds GE HFA Relays HFA 40 milliseconds Trip Units TU 24 milliseconds RPS SCRAM Contactor Contactor 45 milliseconds The BRTs for each component in the loop may be combined together to calculate a BRT for the entire loop logic. Loop type and Loop Logic BRT are taken from NEDO-32291-A Supplement 1, Table 6-2.

Table 3.2.1-3: Selected Loop BRT from NEDO-32291-A, Supplement 1 Loop Trip Unit TU Output Relay Logic Relay Output Relay Loop Logic BRT Type H TU (24 ms) Agastat (140 ms) HFA (40 ms) Contactor (45 ms) 249 ms The difference between the loop maximum allowable response time and the Loop Logic BRT above is considered the maximum allowable Loop Sensor BRT. If the Loop Sensor has a lower BRT than this difference, then the entire loop response time requirements will be met without performance of periodic RTT. For the RPS Reactor Vessel Pressure - High Loops, the required response time of the trip equipment is 550 milliseconds per the JAF Final Safety Analysis Report (FSAR) Table 7.2-5. Note 3 on this table states the following regarding the response time: Sensor is eliminated from response time testing for the RPS actuation logic circuits. Response time testing and conformance to the test acceptance criteria for the remaining channel components includes trip unit and relay logic.

Based on the information above, the sensor BRT is calculated as (550 - 249) = 301 milliseconds.

The sensor for the Reactor Pressure loops is a Rosemount 1153 transmitter that has a BRT of 200 milliseconds per ISP-104A/B. This sensor BRT was determined previously when JAF submitted a Technical Specification (TS) amendment to remove RTT for the sensors of the loops considered in this report under NEDO-32291-A. See JAF TS amendment 235 for additional details. As the sensor BRT is lower that the allowable sensor BRT, NEDO-32291-A Supplement 1 allows us to conclude that surveillance tests other than RTT are sufficient to ensure that the FSAR listed loop response time requirements are met.

3.2.2 REACTOR WATER LEVEL LOW - LEVEL 3:

The Reactor Water Level Low - Level 3 sensors provide input to the RPS Scram Contactors when the water level in the reactor drops below the Level 3 setpoint. Equipment in the Reactor Water Level 3 loops are listed in Table 3.2.2-1 below.

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 8 of 20 Revised Table 3.2.2-1: Reactor Water Level 3 Equipment and Models Sensor MTU TU Output Relay Logic Relay Output Relay 023LT101A 023MTU201A 05AK102A 05AK6A 05AK14A/E (Rosemount 710DU) (Agastat EGPB) (12HFA151A9) (RPS SCRAM Contactor GE CR105) 023LT101B 023MTU201B 05AK102B 05AK6B 05AK14C/G (Rosemount 710DU) (Agastat EGPB) (12HFA151A9) (RPS SCRAM Contactor GE CR105) 023LT101C 023MTU201C 05AK102C 05AK6C 05AK14B/F (Rosemount 710DU) (Agastat EGPB) (12HFA151A9) (RPS SCRAM Contactor GE CR105) 023LT101D 023MTU201D 05AK102D 05AK6D 05AK14D/H (Rosemount 710DU) (Agastat EGPB) (12HFA151A9) (RPS SCRAM Contactor GE CR105)

The components in these loops have been analyzed in NEDO-32291-A Supplement 1. See Section 6.1 of NEDO-32291-A Supplement 1 for details.

These components arranged as shown on the loop drawings and schematics listed in References 8 thru 15 match the Loop Type H as described in Section 6.2 of NEDO-32291-A.

Since the equipment installed in the plant matches the NEDO analyzed configuration, the plant procedures may be compared to the NEDO procedures to determine if they can be applied directly, or if modifications are required to implement the results of the report.

Bounding Response Time The Bounding Response Time (BRT) for a component is the maximum response time that could result from credible, undetected, component failures or degradation. Per NEDO-32291-A Supplement 1, these failures or degradation are not expected to be detectable by any actions other than period Response Time Testing. Failures that result in a response time higher than the BRT are considered detectable by periodic surveillance other than the RTT. The BRT for each component type has been determined in NEDO-32291-A Supplement 1 via FMEA, component specifications, and industry experience. In order to use the determined BRTs, certain procedural requirements must be met. See Section 3.2 for Equipment Requirements.

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 9 of 20 Table 3.2.2-2: Selected Equipment BRT from NEDO-32291-A, Supplement 1 Component Set Abbreviation Bounding Response Time Agastat Relays Agastat 140 milliseconds GE HFA Relays HFA 40 milliseconds Trip Units TU 24 milliseconds RPS SCRAM Contactor Contactor 45 milliseconds The BRTs for each component in the loop may be combined together to calculate a BRT for the entire loop logic. Loop type and Loop Logic BRT are taken from NEDO-32291-A Supplement 1, Table 6-2.

Table 3.2.2-3: Selected Loop BRT from NEDO-32291-A, Supplement 1 Loop Type Trip Unit TU Output Relay Logic Relay Output Relay Loop Logic BRT H TU (24 ms) Agastat (140 ms) HFA (40 ms) Contactor (45 ms) 249 ms The difference between the loop maximum allowable response time and the Loop Logic BRT above is considered the maximum allowable Loop Sensor BRT. If the Loop Sensor has a lower BRT than this difference, then the entire loop response time requirements will be met without performance of periodic RTT. For the RPS Reactor Water Level - Level 3 Loops, the required response time of the trip equipment is 1050 milliseconds per the JAF FSAR Table 7.2-5. Note 3 on this table states the following regarding the response time: Sensor is eliminated from response time testing for the RPS actuation logic circuits.

Response time testing and conformance to the test acceptance criteria for the remaining channel components includes trip unit and relay logic.

Based on the information above, the sensor BRT is calculated as (1050 - 249) = 801 milliseconds.

The sensor for the Reactor Water Level loops is a Rosemount 1153 transmitter that has a BRT of 500 milliseconds per ISP-102A/B. This sensor BRT was determined previously when JAF submitted a Technical Specification amendment to remove RTT for the sensors of the loops considered in this report under NEDO-32291-A. See JAF TS amendment 235 for additional details. As the sensor BRT is lower that the allowable sensor BRT, NEDO-32291-A Supplement 1 allows us to conclude that surveillance tests other than RTT are sufficient to ensure that the FSAR listed loop response time requirements are met.

3.2.3 MAIN STEAM FLOW - HIGH Loop Equipment The Main Steam Line Flow sensors provide input to the MSIV closure logic when the steam flow rate rises above the flow setpoint. Equipment in the MSIV Steam Flow loops are listed in Table 3.2.3-1 below.

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 10 of 20 Revised Table 3.2.3-1: Main Steam Flow Loop Equipment and Models Sensor MTU TU Output Relay Logic Relay Output Relay 02MTU-216A 05A-K113A 16A-K3A 02DPT-116A 16A-K7A (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-217A 05A-K114A 16A-K3A 02DPT-117A 16A-K7A (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-218A 05A-K115A 16A-K3A 02DPT-118A 16A-K7A (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-219A 05A-K116A 16A-K3A 02DPT-119A 16A-K7A (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-216B 05A-K113B 16A-K3B 02DPT-116B 16A-K7B (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-217B 05A-K114B 16A-K3B 02DPT-117B 16A-K7B (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-218B 05A-K115B 16A-K3B 02DPT-118B 16A-K7B (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-219B 05A-K116B 16A-K3B 02DPT-119B 16A-K7B (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-216C 05A-K113C 16A-K3C 02DPT-116C 16A-K7C (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-217C 05A-K114C 16A-K3C 02DPT-117C 16A-K7C (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-218C 05A-K115C 16A-K3C 02DPT-118C 16A-K7C (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-219C 05A-K116C 16A-K3C 02DPT-119C 16A-K7C (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-216D 05A-K113D 16A-K3D 02DPT-116D 16A-K7D (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-217D 05A-K114D 16A-K3D 02DPT-117D 16A-K7D (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-218D 05A-K115D 16A-K3D 02DPT-118D 16A-K7D (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02MTU-219D 05A-K116D 16A-K3D 02DPT-119D 16A-K7D (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9)

The components in these loops have been analyzed in NEDO-32291-A Supplement 1. See Section 6.1 of NEDO-32291-A Supplement 1 for details on the analyzed equipment types.

These components arranged as shown on the loop drawings listed in the References 8 thru 15 match the Loop Type E as described in Section 6.2 of NEDO-32291-A Supplement 1.

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 11 of 20 Since the equipment installed in the plant matches the NEDO analyzed configuration, the plant procedures may be compared to the NEDO procedures to determine if they can be applied directly, or if modifications are required to implement the results of the report.

Bounding response Time The Bounding Response Time (BRT) for a component is the maximum response time that could result from credible, undetected, component failures or degradation. Per NEDO-32291-A Supplement 1, these failures or degradation are not expected to be detectable by any actions other than periodic RTT.

Failures that result in a response time higher than the BRT are considered detectable by periodic surveillance other than the RTT. The BRT for each component type has been determined in NEDO-32291-A Supplement 1 via Failure Modes and Effects Analysis (FMEA), component specifications, and industry experience. In order to use the determined BRTs, certain procedural requirements must be met. See Section 3.2 for Equipment Requirements.

Table 3.2.3-2: Selected Equipment BRT from NEDO-32291-A, Supplement 1 Component Set Abbreviation Bounding Response Time Agastat Relays Agastat 140 milliseconds GE HFA Relays HFA 40 milliseconds Trip Units TU 24 milliseconds The BRTs for each component in the loop may be combined together to calculate a BRT for the entire loop logic. Loop type and Loop Logic BRT are taken from NEDO-32291-A Supplement 1, Table 6-2.

Table 3.2.3-3: Selected Loop BRT from NEDO-32291-A, Supplement 1 Loop Type Trip Unit TU Output Relay Logic Relay Output Relay Loop Logic BRT E TU (24 ms) Agastat (140 ms) HFA (40 ms) HFA (40 ms) 244 ms The difference between the loop maximum allowable response time and the Loop Logic BRT above is considered the maximum allowable Loop Sensor BRT. If the Loop Sensor has a smaller BRT than this difference, then the entire loop response time requirements will be met without periodic RTT.

For the MSIV Main Steam Flow - High Loops, the required response time of the trip equipment is 2500 milliseconds per the JAF Final Safety Analysis Report (FSAR) Table 7.3-12. The Note on this table states the following regarding the response time:

Sensor is eliminated from response time testing for the MISV actuation logic circuits. Response time testing and conformance to the test acceptance criteria for the remaining channel components includes trip unit and relay logic.

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 12 of 20 Based on the information above, the sensor BRT is calculated as (2500 - 244) = 2256 milliseconds.

The sensor for the Steam Flow loops is a Rosemount 1153 transmitter that has a BRT of 700 milliseconds per ISP-106A/B. This sensor BRT was determined previously when JAF submitted a TS amendment to remove RTT for the sensors of the loops considered in this report under NEDO-32291-A. See JAF TS amendment 235 for additional details.

As the sensor BRT is lower that the allowable sensor BRT, NEDO-32291-A Supplement 1 allows us to conclude that surveillance tests other than RTT are sufficient to ensure that the FSAR listed loop response time requirements are met.

3.2.4 MAIN STEAM PRESSURE - LOW Loop Equipment The Main Steam Pressure Low sensors provide input to the MSIV closure logic when the pressure in the main steam lines drops below the setpoint. Equipment in the Main Steam Pressure - Low loops are listed in Table 3.2.4-1 below.

Revised Table 3.2.4-1 Main Steam Pressure - Low Equipment and Models Sensor MTU TU Output Relay Logic Relay Output Relay 02MTU-234A 05A-K121A 16A-K4A 16A-K7A 02PT-134A (Rosemount 710DU) (Agastat EGPB) (12HFA151A9) (12HFA151A9) 02MTU-234B 05A-K121B 16A-K4B 16A-K7B 02PT-134B (Rosemount 710DU) (Agastat EGPB) (12HFA151A9) (12HFA151A9) 02MTU-234C 05A-K121C 16A-K4C 16A-K7C 02PT-134C (Rosemount 710DU) (Agastat EGPB) (12HFA151A9) (12HFA151A9) 02MTU-234D 05A-K121D 16A-K4D 16A-K7D 02PT-134D (Rosemount 710DU) (Agastat EGPB) (12HFA151A9) (12HFA151A9)

The components in these loops have been analyzed in NEDO-32291-A Supplement 1. See Section 6.1 of NEDO-32291-A Supplement 1 for details.

These components arranged as shown on the loop drawings and schematics listed in References 16 thru 25 match the Loop Type E as described in Section 6.2 of NEDO-32291-A Supplement 1.

Since the equipment installed in the plant matches the NEDO analyzed configuration, the plant procedures may be compared to the NEDO procedures to determine if they can be applied directly, or if modifications are required to implement the results of the report.

Bounding response Time The BRT for a component is the maximum response time that could result from credible, undetected, component failures or degradation. Per NEDO-32291-A Supplement, these failures or degradation are not expected to be detectable by any actions other than period Response Time Testing. Failures that

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 13 of 20 result in a response time higher than the BRT are considered detectable by periodic surveillance other than the RTT. The BRT for each component type has been determined in NEDO-32291-A Supplement 1 via FMEA, component specifications, and industry experience. In order to use the determined BRTs, certain procedural requirements must be met. See Section 3.2 for Equipment Requirements.

Table 3.2.4-2: Selected Equipment BRT from NEDO-32291-A, Supplement 1 Component Set Abbreviation Bounding Response Time Agastat Relays Agastat 140 milliseconds GE HFA Relays HFA 40 milliseconds Trip Units TU 24 milliseconds The BRTs for each component in the loop may be combined together to calculate a BRT for the entire loop logic. Loop type and Loop Logic BRT are taken from NEDO-32291-A Supplement 1, Table 6-2.

Table 3.2.4-3: Selected Loop BRT from NEDO-32291-A, Supplement 1 Loop Type Trip Unit TU Output Relay Logic Relay Output Relay Loop Logic BRT E TU (24 ms) Agastat (140 ms) HFA (40 ms) HFA (40 ms) 244 ms The difference between the loop maximum allowable response time and the Loop Logic BRT above is considered the maximum allowable Loop Sensor BRT. If the Loop Sensor has a lower BRT than this difference, then the entire loop response time requirements will be met without periodic RTT.

For the MSIV Main Steam Pressure - Low loops, the required response time of the trip equipment is 1000 milliseconds per the JAF FSAR Table 7.3-12. The note on this table states the following regarding the response time:

Sensor is eliminated from response time testing for the MSIV actuation logic circuits. Response time testing and conformance to the test acceptance criteria for the remaining channel components includes trip unit and relay logic.

Based on the information above, the sensor BRT is calculated as (1000 - 244) = 756 milliseconds.

The sensor for the Main Steam Pressure - Low loops is a Rosemount 1153 transmitter that has a BRT of 200 milliseconds per ISP-105A/B. This sensor BRT was determined previously when JAF submitted a Technical Specification amendment to remove RTT for the sensors of the loops considered in this report under NEDO-32291-A. See JAF TS amendment 235 for additional details.

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 14 of 20 As the sensor BRT is lower that the allowable sensor BRT, NEDO-32291-A Supplement 1 allows us to conclude that surveillance tests other than RTT are sufficient to ensure that the FSAR listed loop response time requirements are met.

3.2.5 REACTOR WATER LEVEL LOW LOW LOW - LEVEL 1 Loop Equipment The Reactor Water Level Low - Level 1 sensors provide input to the MSIV closure logic when the water level in the reactor drops below the Level 1 setpoint. Equipment in the Reactor Water Level 1 loops are listed in Table 3.2.5-1 below.

Revised Table 3.2.5-1: Reactor Water Level 1 Equipment and Models Sensor MTU TU Output Relay Logic Relay Output Relay 02-3MTU-257A 05A-K122A 16A-K1A 02-3LT-57A 16A-K7A (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02-3MTU-257B 05A-K122B 16A-K1B 02-3LT-57B 16A-K7B (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02-3MTU-258A 05A-K122C 16A-K1C 02-3LT-58A 16A-K7C (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9) 02-3LT-58B 02-3MTU-258B 05A-K122D 16A-K1D 16A-K7D (12HFA151A9)

(Rosemount 710DU) (Agastat EGPB) (12HFA151A9)

The components in these loops have been analyzed in NEDO-32291-A Supplement 1. See Section 6.1 of NEDO-32291-A Supplement 1 for details.

These components arranged as shown on the loop drawings and schematics listed in References 16 thru 25 match the Loop Type E as described in Section 6.2 of NEDO-32291-A Supplement 1.

Since the equipment installed in the plant matches the NEDO analyzed configuration, the plant procedures may be compared to the NEDO procedures to determine if they can be applied directly, or if modifications are required to implement the results of the report Bounding Response time The.BRT for a component is the maximum response time that could result from credible, undetected, component failures or degradation. Per NEDO-32291-A Supplement 1, these failures or degradation are not expected to be detectable by any actions other than period Response Time Testing. Failures that result in a response time higher than the BRT are considered detectable by periodic surveillance other than the RTT. The BRT for each component type has been determined in NEDO-32291-A Supplement 1 via FMEA, component specifications, and industry experience. In order to use the determined BRTs, certain procedural requirements must be met. See Section 3.2 for Equipment Requirements.

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 15 of 20 Table 3.2.5-2: Selected Equipment BRT from NEDO-32291-A, Supplement 1 Component Set Abbreviation Bounding Response Time Agastat Relays Agastat 140 milliseconds GE HFA Relays HFA 40 milliseconds Trip Units TU 24 milliseconds The BRTs for each component in the loop may be combined together to calculate a BRT for the entire loop logic. Loop type and Loop Logic BRT are taken from NEDO-32291-A Supplement 1, Table 6-2 Table 3.2.5-3: Selected Loop BRT from NEDO-32291-A, Supplement 1 Loop Loop Logic Trip Unit TU Output Relay Logic Relay Output Relay Type BRT E TU (24 ms) Agastat (140 ms) HFA (40 ms) HFA (40 ms) 244 ms The difference between the loop maximum allowable response time and the Loop Logic BRT above is considered the maximum allowable Loop Sensor BRT. If the Loop Sensor has a smaller BRT than this difference, then the entire loop response time requirements will be met without periodic RTT.

For the MSIV Reactor Water Level Low Low Low - Level 1 Loops, the required response time of the trip equipment is 1000 milliseconds per the JAF FSAR Table 7.3-12. The note on this table states the following regarding the response time:

Sensor is eliminated from response time testing for the MSIV actuation logic circuits. Response time testing and conformance to the test acceptance criteria for the remaining channel components includes trip unit and relay logic.

This sensor BRT was determined previously when JAF submitted a TS amendment to remove RTT for the sensors of the loops considered in this report under NEDO-32291-A. See JAF TS amendment 235 for additional details.

Based on the information above, the sensor BRT is calculated as (1000 - 244) = 756 milliseconds.

The sensor for the Reactor Water Level loops is a Rosemount 1153 transmitter that has a BRT of 200 milliseconds per ISP-103A/B. This sensor BRT was determined previously when JAF submitted a Technical Specification amendment to remove RTT for the sensors of the loops considered in this report under NEDO- 32291-A. See JAF TS amendment 235 for additional details.

As the sensor BRT is lower that the allowable sensor BRT, NEDO-32291-A Supplement 1 allows us to conclude that surveillance tests other than RTT are sufficient to ensure that the FSAR listed loop response time requirements are met.

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 16 of 20

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met. Exelon has determined that the proposed change does not require any exemptions or relief from regulatory requirements, other than the Technical Specifications, and does not affect conformance with any General Design Criteria (GDC) differently than described in the JAF Updated Final Safety Analysis Report (UFSAR). Applicable regulatory requirements will continue to be met, adequate defense-in-depth will be maintained, and sufficient safety margins will be maintained. Exelon adherence to the conditions listed in the NRC Safety Evaluations for the NEDO-32291-A Supplement 1 provides additional assurance that the instrumentation systems will continue to meet the response time requirements of the accident analyses as defined in the UFSAR.

In 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 NRC'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.

4.2 Precedence Similar License Amendment request:

The proposed changes are similar to license amendments issued for a number of other nuclear units.

Specifically, the proposed amendment is similar to amendments issued for Fermi 2 via letter dated October 2, 2002; Edwin I. Hatch Nuclear Plant Unit 2 via letter dated May 17, 2002; Susquehanna Steam Electric Station Units 1 and 2, vial letter dated March 12, 2001, and LaSalle County Station, Units 1 and 2 via letter dated November 19, 2004.

4.3 No Significant Hazards Consideration Exelon determined that the proposed change to eliminate Surveillance Requirement (SR) for Response Time Testing, SR 3.3.1.1.15, for function 3, Reactor Pressure - High, and function 4, Reactor Vessel Water Level - Low (level 3) as well as SR 3.3.6.1.8 from TS Section 3.3.6.1,Table 3.3.6.1-1 Functions 1a Reactor Vessel Water Level - Low Low Low (level 1), 1.b, "Main Steam Line Pressure - Low," and 1c Main Steam Line Flow - High does not involve a significant hazards consideration by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below

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

Response: No.

The proposed amendment to the Technical Specifications (TS) eliminate Surveillance Requirement (SR) for Response Time Testing, SR 3.3.1.1.15, for function 3, Reactor Pressure - High, and function 4, Reactor Vessel Water Level - Low (level 3) as well as SR 3.3.6.1.8 from TS Section 3.3.6.1,Table 3.3.6.1-1 Functions 1a Reactor Vessel Water Level - Low Low Low (level 1), 1.b, "Main Steam Line Pressure -

Low," and 1c Main Steam Line Flow - High is in accordance with NRC approved BWR Owners Group Licensing Topical report (NEDO-33291-A Supplement 1) System Analyses for the Elimination of Selected Response Time Testing requirements, dated October 1999.

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 17 of 20 The proposed change does not result in the alteration of the design, material, or construction standards that were applicable prior to the proposed change. The response time assumptions used in the accident analyses remain unchanged. Only the methodology used for response time verification is changed. As documented in the NEDO-33291-A and Supplement 1, a degraded response time will be detected by other TS required tests. The bounding response time of the relays discussed in the supplement 1 can be used in place of actual measured response times to ensure that the instrumentation systems will meet the response time requirements of the accident analysis. The proposed change will not result in the modification of any system interface that would increase the likelihood of an accident since these events are independent of the proposed change. In addition, the proposed amendment will not change, degrade, or prevent actions, or alter any assumptions previously made in evaluating the radiological consequences of an accident.

In summary, the proposed change does not involve a significant increase in the probability or consequences 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 amendment to the Technical Specifications (TS) to eliminate Surveillance Requirement (SR) for Response Time Testing, SR 3.3.1.1.15, for function 3, Reactor Pressure - High, and function 4, Reactor Vessel Water Level - Low (level 3) as well as SR 3.3.6.1.8 from TS Section 3.3.6.1,Table 3.3.6.1-1 Functions 1a Reactor Vessel Water Level - Low Low Low (level 1), 1.b, "Main Steam Line Pressure -

Low," and 1c Main Steam Line Flow - High is in accordance with NRC approved BWR Owners Group Licensing Topical report (NEDO-33291-A Supplement 1) System Analyses for the Elimination of Selected Response Time Testing requirements, dated October 1999.

The proposed change does not involve physical alteration of the station. No new equipment is being introduced, and installed equipment is not being operated in a new or different manner. There are no setpoints at which protective or mitigative actions are initiated that are affected by this proposed action.

The proposed change does not alter assumptions made in the safety analysis. A review of the failure modes of the affected sensors and relays indicates that a sluggish response of the instruments can be detected by other TS surveillances.

The sensors and relays in the affected channels will be able to meet the bounding response times as defined and presented in NEDO-33291-A and Supplement 1. It has been found acceptable to use component bounding response times in place of actual measured response times to ensure that instrumentation systems will meet response time requirements of the accident analyses. In addition, Exelon adherence to the conditions listed in the NRC Safety Evaluations for NEDO-33291-A and Supplement 1 provides additional assurance that the instrumentation systems will meet the response time requirements of the accident analyses.

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

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 18 of 20

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

Response: No.

The proposed amendment to the Technical Specifications (TS) to eliminate Surveillance Requirement (SR) for Response Time Testing, SR 3.3.1.1.15, for function 3, Reactor Pressure - High, and function 4, Reactor Vessel Water Level - Low (level 3) as well 3.3.6.1.8 from TS Section 3.3.6.1,Table 3.3.6.1-1 Functions 1a Reactor Vessel Water Level - Low Low Low (level 1), 1.b, "Main Steam Line Pressure -

Low," and 1c Main Steam Line High Flow is in accordance with NRC approved BWR Owners Group Licensing Topical report (NEDO-33291-A Supplement 1) System Analyses for the Elimination of Selected Response Time Testing requirements, dated October 1999.

The current response time limits are based on the maximum values assumed in the plant safety analyses, which conservatively establishes the margin of safety. The elimination of the selected response time testing does not affect the probability of the associated systems to perform their intended function within the allowed response time used as the basis for plant safety analyses. This is based on the ability to detect a degraded response time of an instrument or relay by the other required TS tests, component reliability, and redundancy and diversity of the affected functions, as justified in the reviewed and approved NEDO-33291-A Supplement 1.

Plant and system response to an initiating event will remain in compliance within the assumptions of the safety analyses, and therefore, the margin of safety is not affected.

4.4 Conclusions In 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 Commissions 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.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that 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 effluent 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.

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 19 of 20 REFERENCES

1. James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Proposed Change to the Technical Specifications Regarding Response Time testing requirements (JPTS-96-005), letter dated May 30, 1996.

2. Issuance of Amendment for James A. FitzPatrick Nuclear Power Plant (TAC No. M95524),

dated October 28, 1996

3. BWR Owners Group Licensing Topical Report (NEDO-32291-A) System Analyses for the Elimination of Selected Response Time Testing requirements, dated October 1995

4. Letter from U.S. NRC to BWR Owners Group Documenting NRC Review of NEDO-32291-A, Dated December 28, 1994

5. BWR Owners Group Licensing Topical Report (NEDO-32291-A Supplement 1) System Analyses for the Elimination of Selected Response Time Testing requirements, dated October 1999

6. Letter from U. S. NRC to W. Glenn Warren (BWR Owners' Group), "Review of Boiling Water Reactor Owners Group (BWROG) Licensing Topical Report NED0-32291, Supplement 1, System Analyses for Elimination of Selected Response Time Testing Requirements," dated June 11, 1999

7. NUREG-1433, Standard Technical Specifications, General Electric BWR/4 Plants, Volume 1, Revision 4, dated April 2012

8. LP-02-3N, Loop Diagram Nuclear Boiler Instrumentation Reactor Vessel High Pressure Auto SCRAM A1 02-3PT-55A System 02-3, Revision 2

9. LP-02-3P, Loop Diagram Nuclear Boiler Instrumentation Reactor Vessel High Pressure Auto SCRAM B1 02-3PT-55B System 02-3, Revision 1

10. LP-02-3Q, Loop Diagram Nuclear Boiler Instrumentation Reactor Vessel High Pressure Auto SCRAM A2 02-3PT-55C System 02-3, Revision 1

11. LP-02-3R, Loop Diagram Nuclear Boiler Instrumentation Reactor Vessel High Pressure Auto SCRAM B2 02-3PT-55D System 02-3, Revision 2

12. LP-05E, Loop Diagram Reactor Protection System Reactor Low Level Trip Channel A1 02-3LT- 101A System 05, Revision 1

13. LP-05F, Loop Diagram Reactor Protection System Reactor Low Level Trip Channel B1 02-3LT-101B System 05, Revision 1

14. LP-05G, Loop Diagram Reactor Protection System Reactor Low Level Trip Channel A2 02-3LT- 101C System 05, Revision 1

15. LP-05H, Loop Diagram Reactor Protection System Reactor Low Level Trip Channel B2 02-3LT-101D System 05, Revision 1

16. LP-02-3E, LOOP DIAGRAM NBI RECIRC PMP TRIP LEVEL AND PRESSURE, MST VLV CLOSURE LEVEL, AND ARE ATWS PRESSURE A, Revision 3

ENCLOSURE Revision 1 Evaluation of Proposed Changes Page 20 of 20

17. LP-02-3F, LOOP DIAGRAM NBI RECIRC PMP TRIP LEVEL AND PRESSURE, MST VLV CLOSURE LEVEL, AND ARE ATWS PRESSURE B, Revision 3

18. LP-02-3G, LOOP DIAGRAM NBI RECIRC PMP TRIP LEVEL AND PRESSURE, MST VLV CLOSURE LEVEL, AND ARE ATWS PRESSURE A, Revision 3

19. LP-02-3H, LOOP DIAGRAM NBI RECIRC PMP TRIP LEVEL AND PRESSURE, MST VLV CLOSURE LEVEL, AND ARE ATWS PRESSURE B, Revision 3

20. LP-02V, LOOP DIAGRAM MAIN STEAM SYSTEM FLOW MSIV A, B, C, & D DIFFERENTIAL PRESSURE, REVISION 1

21. LP-02W, LOOP DIAGRAM MAIN STEAM SYSTEM FLOW MSIV A, B, C, & D DIFFERENTIAL PRESSURE, REVISION 2

22. LP-02X, LOOP DIAGRAM MAIN STEAM SYSTEM FLOW MSIV A, B, C, & D DIFFERENTIAL PRESSURE, REVISION 1

23. LP-02Y, LOOP DIAGRAM MAIN STEAM SYSTEM FLOW MSIV A, B, C, & D DIFFERENTIAL PRESSURE, REVISION 3

24. LP-02T, LOOP DIAGRAM MAIN STEAM PRESSURE LINES A & C SYS 29, REVISION 2

25. LP-02U, LOOP DIAGRAM MAIN STEAM PRESSURE LINE B & D SYS 29, REVISION 2