ML080870376
| ML080870376 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/29/2008 |
| From: | Peter Bamford NRC/NRR/ADRO/DORL/LPLI-2 |
| To: | Pardee C Exelon Generation Co |
| Bamford, Peter J., NRR/DORL 415-2833 | |
| Shared Package | |
| ml080870366 | List: |
| References | |
| TAC MD5937, TAC MD5938 | |
| Download: ML080870376 (14) | |
Text
May 29, 2008 Mr. Charles G. Pardee Chief Nuclear Officer and Senior Vice President Exelon Generating Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: CHANGES TO ACCIDENT MONITORING INSTRUMENTATION TECHNICAL SPECIFICATIONS (TAC NOS. MD5937 AND MD5938)
Dear Mr. Pardee:
The Commission has issued the enclosed Amendment No. 191 to Facility Operating License No. NPF-39 and Amendment No. 152 to Facility Operating License No. NPF-85, for Limerick Generating Station (LGS), Units 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated June 27, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML071780293).
The amendments consist of changes to the TSs of each unit to delete the operability and surveillance requirements for the drywell air temperature and suppression chamber air temperature. These post-accident monitoring instrumentation requirements are not required to be contained in the plants TSs and are being re-located to the LGS Technical Requirements Manual.
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/
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. 191 to License No. NPF-39
- 2. Amendment No. 152 to License No. NPF-85
- 3. Safety Evaluation cc w/encls: See next page
May 29, 2008 Mr. Charles G. Pardee Chief Nuclear Officer and Senior Vice President Exelon Generating Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: CHANGES TO ACCIDENT MONITORING INSTRUMENTATION TECHNICAL SPECIFICATIONS (TAC NOS. MD5937 AND MD5938)
Dear Mr. Pardee:
The Commission has issued the enclosed Amendment No. 191 to Facility Operating License No. NPF-39 and Amendment No. 152 to Facility Operating License No. NPF-85, for Limerick Generating Station (LGS), Units 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated June 27, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML071780293).
The amendments consist of changes to the TSs of each unit to delete the operability and surveillance requirements for the drywell air temperature and suppression chamber air temperature. These post-accident monitoring instrumentation requirements are not required to be contained in the plants TSs and are being re-located to the LGS Technical Requirements Manual.
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/
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. 191 to License No. NPF-39
- 2. Amendment No. 152 to License No. NPF-85
- 3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
PUBLIC LPL1-2 R/F RidsNrrDorlLpl1-2 RidsNrrPMPBamford Rids NrrLAABaxter GHill,OIS (2)
RidsNrrDorlDpr RidsOgcRp RidsNrrDeEicb RidsNrrDirsItsb RidsRgn1MailCenter RidsAcrsAcnw&mMailCenter KScales, NRR BMarcus, NRR Package Accession Number: ML080870366; Amendment Accession Number: ML080870376; Tech Specs for Amd 191 : ML080870400; Tech Specs for Amd 152 : ML080870420
- by memo LPLI-2/PM LPLI-2/LA EICB/BC ITSB/BC OGC LPLI-2/BC Name PBamford ABaxter WKemper*
RElliott BMizuno HChernoff Date 03/27/2008 04/08/2008 03/17/2008 04/16/2008 04/22/2008 5/29/08 Official Record Copy
Christopher Mudrick Site Vice President Limerick Generating Station Exelon Generation Company, LLC 3146 Sanatoga Road Sanatoga, PA 19464 Ed Callan, Plant Manager Limerick Generating Station Exelon Generation Company, LLC 3146 Santoga Road Sanatoga, PA 19464 Manager Regulatory Assurance - Limerick Generating Station Exelon Generation Company, LLC 3146 Sanatoga Road Sanatoga, PA 19464 Senior Vice President - Mid-Atlantic Operations Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Chief Operating Officer-Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Senior Vice President -Operations Support Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Manager Licensing Exelon Generation Company, LLC Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Correspondence Control Desk Exelon Generation Company, LLC 200 Exelon Way, KSA 1-N-1 Kennett Square, PA 19348 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector U.S. Nuclear Regulatory Commission Limerick Generating Station P.O. Box 596 Pottstown, PA 19464 Library U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Director, Bureau of Radiation Protection Pennsylvania Dept. of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Chairman Board of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 J. Bradley Fewell, Esquire Associate General Counsel Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Mr. Charles G. Pardee Chief Nuclear Officer and Senior Vice President Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348
EXELON GENERATION COMPANY, LLC DOCKET NO. 50-352 LIMERICK GENERATING STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 191 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 27, 2007, 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. 191, are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
This license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance. Implementation of the amendment shall include updating the Updated Final Safety Analysis Report (UFSAR) in accordance with 10 CFR 50.71(e). This update shall include the effects of all safety analyses and evaluations performed by the licensee in support of the amendment. Specifically, the UFSAR update shall include, but not be limited to: a statement that the Technical Requirements Manual (TRM) is treated in a manner consistent with procedures fully or partially described in the UFSAR. For the purposes of 10 CFR 50.59, information presented in the TRM is considered to be information described in the UFSAR, and therefore, is to be treated at the same level as information presented in the UFSAR.
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: May 29, 2008
ATTACHMENT TO LICENSE AMENDMENT NO. 191 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 3/4 3-85 3/4 3-85 3/4 3-87 3/4 3-87
EXELON GENERATION COMPANY, LLC DOCKET NO. 50-353 LIMERICK GENERATING STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 152 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 27, 2007, 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. 152, are hereby incorporated into this license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
This license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance. Implementation of the amendment shall include updating the Updated Final Safety Analysis Report (UFSAR) in accordance with 10 CFR 50.71(e). This update shall include the effects of all safety analyses and evaluations performed by the licensee in support of the amendment. Specifically, the UFSAR update shall include, but not be limited to: a statement that the Technical Requirements Manual (TRM) is treated in a manner consistent with procedures fully or partially described in the UFSAR. For the purposes of 10 CFR 50.59, information presented in the TRM is considered to be information described in the UFSAR, and therefore, is to be treated at the same level as information presented in the UFSAR.
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: May 29, 2008
ATTACHMENT TO LICENSE AMENDMENT NO. 152 FACILITY OPERATING LICENSE NO. NPF-85 DOCKET NO. 50-353 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 3/4 3-85 3/4 3-85 3/4 3-87 3/4 3-87
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 191 TO FACILITY OPERATING LICENSE NO. NPF-39 AND AMENDMENT NO. 152 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 27, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML071780293), Exelon Generation Company, LLC (Exelon, or the licensee) requested changes to the Technical Specifications (TSs) for the Limerick Generating Station (LGS), Units 1 and 2. The proposed changes request the relocation of the operability and surveillance requirements for the drywell air temperature and suppression chamber air temperature instrumentation from LGS TSs sections 3.3.7.5, Accident Monitoring Instrumentation, and 4.3.7.5, Accident Monitoring Instrumentation Surveillance Requirements, to the LGS Technical Requirements Manual (TRM).
2.0 REGULATORY EVALUATION
Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36 establishes the regulatory requirements for TS content. The requirements emphasize preventing accidents and mitigating accident consequences. Applicants are expected to incorporate into their TSs those items that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity (see Statement of Consideration, Technical Specifications for Facility Licenses; Safety Analysis Reports, December 17, 1968 (33 FR 18610)). Section 50.36 of 10 CFR requires that TSs include items in the following specific categories: (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation (LCOs);
(3) surveillance requirements (SRs); (4) design features; (5) administrative controls; (6) decommissioning; (7) initial notification; and (8) written reports. However, the rule does not specify the format and content for TS categories.
Accident monitoring instrumentation is provided to monitor variables and systems over their anticipated ranges for accident conditions, as appropriate, to ensure adequate safety during and following accidents. These instruments are used by the control room operating personnel to perform their role in the evaluation, assessment, and monitoring of events, and execution of control room functions. American National Standards Institute/American Nuclear Society N4.5-1980, Criteria for Accident Monitoring Functions in Light-Water-Cooled Reactors, delineates criteria for determining the variables to be monitored in the control room by the operator. Instrumentation designated as Types A through D aid the designer in selecting the accident monitoring instrumentation and applicable criteria. Categories 1, 2 and 3 separate the Type criteria into groups for a graded approach to requirements depending on the importance to safety or the measurement of a specific variable. Regulatory Guide (RG) 1.97, Instrumentation for Light-Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision 2, describes a method acceptable to the NRC staff for complying with the requirement to provide instrumentation for monitoring plant variables and systems during and following an accident. As specified in the LGS Updated Final Safety Analysis Report (UFSAR), sections 1.8 and 7.5.2.5.1.1.2, LGS implements RG 1.97, except where deviations from the guide are justified technically and can be implemented without disrupting the general intent of the guide.
RG 1.97, recommends that Type A instrumentation be provided for variables that provide primary information needed by the control room operating personnel to take specified manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for design basis events. RG 1.97, Category 1 provides the most stringent design and qualification criteria and is intended for key variables.
On July 22, 1993, the Nuclear Regulatory Commission issued its Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors, indicating that satisfying the guidance in the policy statement also satisfies Section 182a of the Atomic Energy Act and 10 CFR 50.36 (58 FR 39132). The Final Policy Statement described the improved Standard Technical Specification (STS) safety benefits and encouraged licensees to use the improved STS as the basis for plant-specific TS amendments and for complete conversions to the improved STS. LCO requirements that do not fall within or satisfy the criteria described in the Final Policy Statement may be relocated to licensee-controlled documents. According to the Final Policy Statement, this applies to facilities that are converting to the improved STS as well as for facilities with custom TS or the original STS. Thus, this approach is applicable to LGS, even though the station has not yet adopted the improved STS. The criteria described in the Final Policy Statement have been codified in 10 CFR 50.36 (60 FR 36953, July 19, 1995).
In development of the Boiling Water Reactor (BWR)/4 STS, the NRC staff documented deterministic screening criteria for post-accident monitoring instrumentation in a letter dated May 7, 1988, from T.E. Murley (NRC) to R. F. Janecek (BWR Owners Group) (ADAMS Accession No. ML8805240041). The NRC staff position detailed in this letter is that all plant-specific RG 1.97, Type A instruments specified in the plant's Safety Evaluation Report on RG 1.97, and all RG 1.97 Category 1 instruments, meet the provisions of 10 CFR 50.36(d)(ii) and therefore, are to be included in the facility TSs.
RG 1.97, Type D variables are those variables that provide information to indicate the operation of individual safety systems and other systems important to safety. These variables are to assist the operator make appropriate decisions in using the individual systems important to safety in mitigating the consequences of an accident.
3.0 TECHNICAL EVALUATION
The licensee submitted a license amendment request which proposes TS changes associated with Accident Monitoring Instrumentation and Accident Monitoring Instrumentation Surveillance Requirements. The proposed changes requested by this amendment are described below:
TS TABLE 3.3.7.5-1, Accident Monitoring Instrumentation
- 1.
Relocate Item 5, Suppression Chamber Air Temperature, from TS Table 3.3.7.5-1, "Accident Monitoring Instrumentation, on TS page 3/4 3-85, to the TRM. This table identifies the operability requirements for this instrumentation.
- 2.
Relocate Item 7, Drywell Air Temperature, from TS Table 3.3.7.5-1, Accident Monitoring Instrumentation, on TS page 3/4 3-85, to the TRM. This table identifies the operability requirements for this instrumentation.
TS TABLE 4.3.7.5-1, Accident Monitoring Instrumentation Surveillance Requirements
- 1.
Relocate Item 5, Suppression Chamber Air Temperature, from TS Table 4.3.7.5-1, Accident Monitoring Instrumentation Surveillance Requirements, on TS page 3/4 3-87, to the TRM. This table identifies the surveillance requirements for this instrumentation.
- 2.
Relocate Item 7, Drywell Air Temperature, from TS Table 4.3.7.5-1, Accident Monitoring Instrumentation Surveillance Requirements, on TS page 3/4 3-87, to the TRM. This table identifies the surveillance requirements for this instrumentation.
The drywell air temperature and suppression chamber air temperature instrumentation are not used to detect, and indicate in the control room, a significant abnormal degradation of the RCPB and thus are not covered by Criterion 1 of 10 CFR 50.36(d)(2)(ii). These instruments are not process variables, design features, or operating restrictions that are an initial condition of a DBA or transient analysis that assumes the failure of or presents a challenge to the integrity of a fission product barrier and thus are not covered by Criterion 2 of 10 CFR 50.36(d)(2)(ii).
Regarding the remaining two criterion of 10 CFR 50.36(d)(2)(ii), RG 1.97, Revision 2, designates drywell air temperature instrumentation as Type D, Category 2 instrumentation. This designation has been confirmed on a plant-specific basis as detailed in LGS UFSAR Table 7.5-3. RG 1.97, Revision 2, does not include suppression chamber air temperature as an accident monitoring variable and likewise the LGS UFSAR does not specifically identify suppression chamber air temperature as a RG 1.97 variable. However LGS UFSAR section 7.5 describes the use of suppression chamber air temperature for monitoring the effectiveness of suppression chamber spray flow (a Type D, category 2 variable). Thus, since these two parameters are not classified as RG 1.97 Type A or Category 1 variables, the NRC staff concludes that suppression chamber air temperature and drywell air temperature do not fall under the provisions of 10 CFR 50.36 (d)(2)(ii).
Based on the above evaluation, the NRC staff concludes that the licensees proposed changes to relocate operability and surveillance requirements for Accident Monitoring Instrumentation from TSs Sections 3.3.7.5, Accident Monitoring Instrumentation, and 4.3.7.5, Accident Monitoring Instrumentation Surveillance Requirements, to the TRM are consistent with the provisions of 10 CFR 50.36, and are, therefore, 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 51860). 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:
Kerby Scales Barry Marcus Peter Bamford Date: May 29, 2008