ML071760167

License Amendments, Issuance of Amendment Incorporation of Revised 10 CFR Part 20 Requirements Into the Technical Specifications

ML071760167
Person / Time
Site:	Limerick
Issue date:	06/29/2007
From:	Peter Bamford NRC/NRR/ADRO/DORL/LPLI-2
To:	Crane C AmerGen Energy Co
Bamford, Peter J., NRR/DORL 415-2833
Shared Package
ml071760176	List: ML071760167 ML071860406
References
TAC MD4946, TAC MD4947
Download: ML071760167 (16)

Text

June 29, 2007 Mr. Christopher M. Crane President and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT RE: INCORPORATION OF REVISED 10 CFR PART 20 REQUIREMENTS INTO THE TECHNICAL SPECIFICATIONS (TAC NOS.

MD4946 AND MD4947)

Dear Mr. Crane:

The Commission has issued the enclosed Amendment No. 187 to Facility Operating License No. NPF-39 and Amendment No. 148 to Facility Operating License No. NPF-85, for Limerick Generating Station, Units 1 and 2. This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated June 2, 2006.

This amendment revises the TSs to incorporate revised requirements in Title 10 of the Code of Federal Regulations, Part 20. Specifically, the amendment revises the definitions for Members of the Public and Unrestricted Area, adds a definition for Restricted Area, revises the requirements for limitations on the concentrations of radioactive material released in liquid and gaseous effluents, and revises the references for radioactive effluent control requirements.

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

Sincerely,

/ra/ (John D. Hughey for)

Peter Bamford, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 187 to License No. NPF-39

2. Amendment No. 148 to License No. NPF-85

3. Safety Evaluation cc w/encls: See next page

June 29, 2007 Mr. Christopher M. Crane President and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT RE: INCORPORATION OF REVISED 10 CFR PART 20 REQUIREMENTS INTO THE TECHNICAL SPECIFICATIONS (TAC NOS.

MD4946 AND MD4947)

Dear Mr. Crane:

The Commission has issued the enclosed Amendment No. 187 to Facility Operating License No. NPF-39 and Amendment No. 148 to Facility Operating License No. NPF-85, for Limerick Generating Station, Units 1 and 2. This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated June 2, 2006.

This amendment revises the TSs to incorporate revised requirements in Title 10 of the Code of Federal Regulations, Part 20. Specifically, the amendment revises the definitions for Members of the Public and Unrestricted Area, adds a definition for Restricted Area, revises the requirements for limitations on the concentrations of radioactive material released in liquid and gaseous effluents, and revises the references for radioactive effluent control requirements.

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

Sincerely,

/ra/ (John D. Hughey for)

Peter Bamford, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 187 to License No. NPF-39

2. Amendment No. 148 to License No. NPF-85

3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC LPLI-2 R/F RidsNrrDorlLplI-2 RidsNrrPMPBamford RidsNrrDorlDpr GHill,OIS (4) EKeegan RidsNrrLAEWhitt RidsNrrDirsItsb RidsOgsRp RidsRgn1MailCenter RidsAcrsAcnwMailCenter RidsNrrDirsIhpb Amendment Accession Number: ML071760167 Tech Spec Pages: ML071860404 (amd#187); ML071860406 (amd#148); Package Accession Number: ML071760176 OFFICE LPLI-2/PM LPLI-2/PM LPL3-2/LA NRR/ITSB/BC NRR/IHPB/BC OGC NRR/LPLI-2/BC NAME JHughey PBamford EWhitt TKobetz RPedersen DRoth HChernoff DATE 6/29/07 6/25/07 6/26/07 6/26/07 6/28/07 6/29/07 6/29/07 OFFICIAL RECORD COPY

Limerick Generating Station, Unit Nos. 1 and 2 cc:

Site Vice President Regional Administrator, Region I Limerick Generating Station U.S. Nuclear Regulatory Commission Exelon Generation Company, LLC 475 Allendale Road P.O. Box 2300 King of Prussia, PA 19406 Sanatoga, PA 19464 Senior Resident Inspector Plant Manager U.S. Nuclear Regulatory Commission Limerick Generating Station Limerick Generating Station Exelon Generation Company, LLC P.O. Box 596 P.O. Box 2300 Pottstown, PA 19464 Sanatoga, PA 19464 Library Regulatory Assurance Manager - Limerick U.S. Nuclear Regulatory Commission Exelon Generation Company, LLC Region I P.O. Box 2300 475 Allendale Road Sanatoga, PA 19464 King of Prussia, PA 19406 Vice President - Operations, Mid-Atlantic Director, Bureau of Radiation Protection Exelon Generation Company, LLC Pennsylvania Dept. of Environmental 200 Exelon Way, KSA 3-N Protection Kennett Square, PA 19348 Rachel Carson State Office Building P.O. Box 8469 Vice President Harrisburg, PA 17105-8469 Licensing and Regulatory Affairs Exelon Generation Company, LLC Chairman 4300 Winfield Road Board of Supervisors of Limerick Township Warrenville, IL 60555 646 West Ridge Pike Linfield, PA 19468 Director Licensing and Regulatory Affairs Dr. Judith Johnsrud Exelon Generation Company, LLC National Energy Committee 200 Exelon Way, KSA 3-E Sierra Club Kennett Square, PA 19348 433 Orlando Avenue State College, PA 16803 Manager Licensing Limerick Generating Station Associate General Counsel Exelon Generation Company, LLC Exelon Generating Company, LLC 200 Exelon Way, KSA 3-E 4300 Winfield Road Kennett Square, PA 19348 Warrenville, IL 60555 Correspondence Control Desk Exelon Generation Company, LLC P.O. Box 160 Kennett Square, PA 19348

Limerick Generating Station, Unit Nos. 1 and 2 cc:

Mr. Christopher M. Crane President & Chief Nuclear Officer Exelon Generating Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-352 LIMERICK GENERATING STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 187 License No. NPF-39

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

A. The application for amendment by Exelon Generation Company, LLC (the licensee), dated June 2, 2006, 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.

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 Facility Operating License No. NPF-39 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. , are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/ra/

Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance: June 29, 2007

ATTACHMENT TO LICENSE AMENDMENT NO. 187 FACILITY OPERATING LICENSE NO. NPF-39 DOCKET NO. 50-352 Replace the following page of the Facility Operating License with the revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas 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 1-4 1-4 1-7 1-7 1-8 1-8 6-14a 6-14a 6-22 6-22

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 148 License No. NPF-85

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

A. The application for amendment by Exelon Generation Company, LLC (the licensee) dated June 2, 2006, 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.

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 Facility Operating License No. NPF-85 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. , are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/ra/

Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance: June 29, 2007

ATTACHMENT TO LICENSE AMENDMENT NO. 148 FACILITY OPERATING LICENSE NO. NPF-85 DOCKET NO. 50-353 Replace the following page of the Facility Operating License with the attached revised page.

The revised page is identified by amendment number and contains marginal lines indicating the areas 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 1-4 1-4 1-7 1-7 1-8 1-8 6-14a 6-14a 6-22 6-22

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 187 TO FACILITY OPERATING LICENSE NO. NPF-39 AND AMENDMENT NO. 148 TO FACILITY OPERATING LICENSE NO. NPF-85 EXELON GENERATION COMPANY, LLC LIMERICK GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353

1.0 INTRODUCTION

By application dated June 2, 2006, Exelon Generation Company, LLC (the licensee) requested changes to the Technical Specifications (TSs) for the Limerick Generating Station (LGS),

Units 1 and 2. The NRC staffs original proposed no significant hazards consideration determination was published in the Federal Register on April 10, 2007 (72 FR 17949).

This amendment would revise the TSs to incorporate revised requirements in Title 10 of the Code of Federal Regulations (10 CFR), Part 20, Standards for Protection Against Radiation.

Specifically, the amendment would revise the definitions for Members of the Public and Unrestricted Area, add a definition for Restricted Area, revise the requirements for limitations on the concentrations of radioactive material released in liquid and gaseous effluents, and revise the references for radioactive effluent control requirements. Portions of this change are consistent with TS Task Force (TSTF) Change Traveler No. 258-A (TSTF-258-A), Rev. 4, Changes to Section 5.0, Administrative Controls.

2.0 REGULATORY EVALUATION

The applicable regulatory requirements and guidelines for this License Amendment Request (LAR) are:

1. 10 CFR Part 20

2. 10 CFR Part 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion As Low As Is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents

3. 10 CFR 50.36a, Technical specifications on effluents from nuclear power reactors

4. TSTF-258-A, Revision 4

5. NUREG-1433, Revision 3.0, Standard Technical Specifications General Electric Plants, BWR/4"

6. NUREG-1302, Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors.

In 1994, 10 CFR Part 20 was updated. Implementation requirements were specified in 10 CFR 20.1008. As part of this change, dose limits for individual members of the public resulting from plant operations, were reduced from 500 millirem/year to 100 millirem/year, total effective dose equivalent, as specified in 10 CFR 20.1301.

In addition to the requirements in 10 CFR Part 20, controls over the content of licensee TSs relating to radioactive effluents are specified in 10 CFR 50.36a. Section 50.36a of 10 CFR requires licensees to maintain control over radioactive material in gaseous and liquid effluents released to unrestricted areas to levels that are as low as reasonably achievable (ALARA). For power reactors Appendix I to 10 CFR Part 50 contains numerical guides provided to meet the ALARA requirement. It specifies that the total quantity of radioactive material released from a site shall be such that it does not result in an estimated annual dose or dose commitment of more than 3 millirem total body or 10 millirem to any organ to an individual in an unrestricted area (liquid releases). It also specifies no more than 10 millirads gamma or 20 millirads beta for annual gaseous effluents. Thus Appendix I contains much more stringent radiological criteria than the regulatory limits specified in 10 CFR Part 20.

Additionally, the allowable instantaneous dose rates normally specified in the plant TS for effluents were chosen by the NRC staff to keep annual average releases of radioactive material in gaseous and liquid effluents to within the dose values specified in Appendix I of 10 CFR Part

50. As specified in NUREG-1302, values corresponding to a dose rate of 500 mrem/year have been shown to be acceptable as a TS limit for liquid effluents to establish a high likelihood that the Appendix I yearly ALARA criteria are met. Likewise limitations on gaseous effluents of 500 mrem/year to the total body, and 3000 mrem/year to the skin (from noble gases) as well as 1500 mrem/yr to any organ from Iodine-131, Iodine-133, tritium and all particulate radionuclides with half-lives greater than 8 days have also been shown to provide assurance of operation within the Appendix I criteria.

Appendix B to 10 CFR Part 20 contains a tabulated listing of effluent concentrations (Table 2, columns 1 and 2) that correspond to concentrations which would result in a total effective dose equivalent of 50 mrem to a member of the public in an unrestricted area if continuously inhaled or ingested over the course of one year. One of the useful purposes of this table, in conjunction with criteria in the plant TSs, is to provide a means for a licensee to calculate an instantaneous release rate that may be applied to site effluents in order to conform to the TS effluent release rate controls listed above.

3.0 TECHNICAL EVALUATION

LGS, Unit 1 and Unit 2 have separate TS. The following changes are identical for both units.

The licensees proposed changes and NRC staffs evaluation of the changes, are discussed below.

3.1 Definitions 3.1.1 Proposed Changes Definition 1.22, MEMBER(S) OF THE PUBLIC will be revised to state: Member of the Public means any individual except when that individual is receiving an occupational dose.

Definition 1.36a, RESTRICTED AREA, will be added and state: Restricted area means an area, access to which is limited by the licensee for the purpose of protecting individuals against undue risk from exposure to radiation and radioactive materials. Restricted area does not include areas used as residential quarters, but separate rooms in a residential building may be set apart as a restricted area.

Definition 1.45, UNRESTRICTED AREA, will be revised to state: Unrestricted Area means an area, access to which is neither limited nor controlled by the licensee.

3.1.2 NRC Staff Evaluation Revising the definitions for the terms MEMBER(S) OF THE PUBLIC and UNRESTRICTED AREA, and adding the definition for RESTRICTED AREA, make the LGS TS definitions consistent with the definitions provided in 10 CFR Part 20.

The NRC staff finds that the change ensures consistency between the TS and the regulations with no impact on the safety of the units or to members of the public and is therefore, acceptable.

3.2 TS Section 6.8.4.d.2 3.2.1 Proposed Changes TS will be revised to read 10 times the concentration values in 10 CFR Part 20, Appendix B, Table 2, Column 2.

3.2.2 NRC Staff Evaluation The existing LGS TS for both Unit 1 and Unit 2 reference the old (pre-1994) 10 CFR Part 20, Appendix B, Table II, as a release rate control. This proposed change will replace the reference to the old 10 CFR Part 20, Appendix B, Table II with the revised 10 CFR Part 20, Appendix B, Table 2. The factor of 10 that is being applied to the 10 CFR Part 20, Appendix B, Table 2 effluent concentration values will maintain the same level of radioactive effluent control as had previously existed under the old 10 CFR Part 20, Appendix B, Table II reference.

Paragraph 50.36a contains TS requirements regarding ALARA for liquid and gaseous effluents and also allows the licensee the flexibility of allowing releases which temporarily permit higher doses as long as the licensee meets the annual dose limits in 10 CFR 20.1301 and the dose design objectives stated in 10 CFR Part 50, Appendix I.

An instantaneous release concentration which corresponds to a dose rate of 500 mrem/year is acceptable as a TS limit for liquid effluents because the annual dose limits in 10 CFR 20.1301

and the dose design objectives in 10 CFR Part 50, Appendix I must still be met. By meeting the dose design objectives in 10 CFR Part 50, Appendix I, the doses are therefore considered ALARA.

This change is intended to eliminate possible confusion or improper implementation of the 1994 revised 10 CFR Part 20 requirements. It provides sufficient controls over instantaneous release rates to ensure that the annual dose guidelines of 10 CFR 50, Appendix I and the limits of 10 CFR 20.1301 will be met. On this basis, the NRC staff finds the proposed change acceptable.

3.3 TS Section 6.8.4.d.3 3.3.1 Proposed Changes TS will be revised to reference 10 CFR 20.1302 instead of 10 CFR 20.106.

3.3.2 NRC Staff Evaluation The 1994 revision of 10 CFR Part 20 replaced 10 CFR 20.106 with 10 CFR 20.1301 and 10 CFR 20.1302. Section 20.1301 of 10 CFR contains the requirements for dose limits for individual members of the public, and 10 CFR 20.1302 contains the requirements for compliance with the dose limits. This change therefore provides a clear link between the TS and the required dose limits of 10 CFR Part 20. On this basis, the NRC staff finds the proposed change acceptable.

3.4 TS Section 6.8.4.d.7 3.4.1 Proposed Changes TS will be revised to state the following:

Limitations on the dose rate resulting from radioactive material released in gaseous effluents from the site to areas at or beyond the SITE BOUNDARY shall be limited to the following:

a. For noble gases: less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin, and

b. For iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days: less than or equal to 1500 mrem/yr to any organ.

3.4.2 NRC Staff Evaluation The existing LGS TS for both Unit 1 and Unit 2 reference the old (pre-1994) 10 CFR Part 20, Appendix B, Table II as a release rate control. This proposed change will replace the reference to the old 10 CFR Part 20, Appendix B, Table II with the revised 10 CFR Part 20, Appendix B, Table 2.

The concentrations listed in the old 10 CFR Part 20, Appendix B, Table II are values based on maximum permissible concentrations which relate to an annual dose of 500 mrem. The

gaseous effluent concentration limits listed in the revised 10 CFR Part 20, Appendix B, Table 2 are based on an annual dose of 50 mrem for isotopes for which inhalation or ingestion is limiting or 100 mrem for isotopes for which submersion (noble gases) is limiting.

Paragraph 50.36a contains the TS requirements regarding ALARA for liquid and gaseous effluents and also allows the licensee the flexibility of allowing releases which temporarily permit higher doses as long as the licensee meets the annual dose limits in 10 CFR 20.1301 and the dose design objectives stated in 10 CFR Part 50, Appendix I.

Release concentrations corresponding to limiting dose rates at the site boundary from noble gases less than or equal 500 mrem/year to the whole body and 3000 mrem/year to the skin, and less than or equal to 1500 mrem/year to any organ from Iodine-131, Iodine-133, for tritium and all radionuclides in particulate form with half-lives greater than eight days are acceptable as TS release rate controls for gaseous effluents to assure that the annual dose limits in 10 CFR 20.1301 and the dose design objectives stated in 10 CFR Part 50, Appendix I are not likely to be exceeded.

This change is intended to eliminate possible confusion or improper implementation of the revised 10 CFR Part 20 requirements. It provides sufficient controls over instantaneous release rates to ensure that the annual dose guidelines of 10 CFR Part 50, Appendix I and the limits of 10 CFR 20.1301 will be met. On this basis, the NRC staff finds the proposed change acceptable.

3.5 TS Section 6.14.1.a.2 3.5.1 Proposed Changes TS will be revised to reference 10 CFR 20.1302 instead of 10 CFR 20.106.

3.5.2 NRC Staff Evaluation The 1994 revision of 10 CFR Part 20 replaced 10 CFR 20.106 with 10 CFR 20.1301 and 10 CFR 20.1302. Section 20.1301 of 10 CFR contains the requirements for dose limits for individual members of the public, and 10 CFR 20.1302 contains the requirements for compliance with the dose limits. This change therefore provides a clear link between the TS and the required dose limits of 10 CFR Part 20. On this basis, the NRC staff finds the proposed change acceptable

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is

no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (72 FR 17949). Accordingly, the amendment meets 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 amendment.

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) 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.

Principal Contributors: E. Keegan P. Bamford Date: June 29, 2007