View source for JAFP-25-0034, License Amendment Request for Proposed Changes to the Technical Specification Primary Containment Isolation Instrumentation Tables and New Main Steam Tunnel Area Temperature Technical Specification 3.7.8

{{Adams
| number = ML25149A172
| issue date = 05/29/2025
| title = License Amendment Request for Proposed Changes to the Technical Specification Primary Containment Isolation Instrumentation Tables and New Main Steam Tunnel Area Temperature Technical Specification 3.7.8
| author name = Knowles J
| author affiliation = Constellation Energy Generation, LLC
| addressee name = 
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000333
| license number = DPR-059
| contact person = 
| case reference number = JAFP-25-0034
| document type = Letter type:JAFP, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 1
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:200 Energy Way Kennett Square, PA 19348 www.constellation.com 10 CFR 50.90 JAFP-25-0034 May , 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

==Subject:==
License Amendment Request for Proposed Changes to the Technical Specification Primary Containment Isolation Instrumentation Tables and New Main Steam Tunnel Area Temperature Technical Specification 3.7.8 In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-59 for James A.
FitzPatrick Nuclear Power Plant (JAF).
The proposed change removes Function 1.e, "Main Steam Line Tunnel Area Temperature - High,"
and inserts the word "Deleted" in Table 3.3.6.1-1 Primary Containment Isolation Instrumentation.
Deletion of Function 1.e does not require modification to any Actions or Surveillance Requirements.
The proposed change adds a new TS 3.7.8, "Main Steam Tunnel (MST) Area Temperature." The new Limiting Condition for Operation (LCO) 3.7.8 requires the Main Steam Tunnel maximum temperature to be 195&deg;F. The specification is applicable in Modes 1, 2, and 3, the same as existing Function 1.e.
Surveillance Requirement (SR) 3.7.8.1 requires verification that the MST area temperature is 195&deg;F on a frequency controlled by the Surveillance Frequency Control Program (SFCP). The initial frequency will be 24 hours.
In the proposed TS, if the MST Area maximum temperature exceeds 195&deg;F, immediate action is required to verify there is no leakage from the Main Steam Line (MSL) pressure boundary, and periodic verification every 12 hours thereafter. If it cannot be verified that there is no leakage from the Main Steam Line (MSL) pressure boundary or if the periodic verification is not performed, a plant shutdown is required. The plant must be in Mode 3 (Hot Shutdown) within 12 hours and Mode 4 (Cold Shutdown) within 36 hours.
The existing leak detection instrumentation is not intended to be changed associated with this license amendment, outside of removing the automatic Main Steam Line Isolation.
CEG has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92, "Issuance of amendment."

2 License Amendment Request Proposed Changes to MSL Temperature Isolation Signal Docket No. 50-333 0D\\ , 2025 Page 2 The proposed changes have been reviewed by the JAF Plant Operations Review Committee in accordance with the requirements of the CEG Quality Assurance Program.
This amendment request contains no new regulatory commitments. provides the evaluation of the proposed changes. Attachment 2 provides a copy of the marked-up TS pages that reflect the proposed changes. Attachment 3 provides a copy of the marked-up TS Bases (for information only).
CEG requests approval of the proposed amendment by May 31, 2026. Upon NRC approval, the amendment shall be implemented within 30 days of issuance.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),
CEG is notifying the State of New York of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.
Should you have any questions concerning this letter, please contact Michael Henry at (267)533-5382.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the th day of May 2025.
Respectfully, Justin Knowles Sr. Manager - Licensing Constellation Energy Generation, LLC Attachment(s):
1.
Evaluation of Proposed Changes 2.
Markup of Proposed Technical Specification Pages 3.
Markup of Proposed Technical Specification Bases (For Information Only) cc:
USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, JAF USNRC Project Manager, JAF A. Kauk, NYSPSC A.L. Peterson, NYSERDA Knowles, Justin W
Digitally signed by Knowles, Justin W Date: 2025.05.29 12:38:38 
-04'00'

ATTACHMENT 1 License Amendment Request James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 EVLUATION OF PROPOSED CHANGES 

==Subject:==
License Amendment Request for Proposed Changes to the Technical Specification Primary Containment Isolation Instrumentation Tables and New Main Steam Tunnel Area Temperature Technical Specification 3.7.8 1.0 

==SUMMARY==
DESCRIPTION 2.0 DETAILED DESCRIPTION 

==3.0 TECHNICAL EVALUATION==
==4.0 REGULATORY EVALUATION==
4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions 

==5.0 ENVIRONMENTAL CONSIDERATION==
==6.0 REFERENCES==
License Amendment Request Proposed Changes to MSL Tunnel Temperature Isolation Signal Docket No. 50-333 2
1.0 

==SUMMARY==
DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF).
The proposed change removes Function 1.e, "Main Steam Tunnel Area Temperature - High,"
and inserts the word "Deleted" in Table 3.3.6.1-1 Primary Containment Isolation Instrumentation, Deletion of Function 1.e does not require modification to any Actions or Surveillance Requirements.
The proposed change adds a new TS 3.7.8, "Main Steam Tunnel (MST) Area Temperature."
The new Limiting Condition for Operation (LCO) 3.7.8 requires the MST Area maximum temperature to be 195&deg;F. The specification is applicable in Modes 1, 2, and 3, the same as existing Function 1.e. Surveillance Requirement (SR) 3.7.8.1 requires verification that the MST Area temperature is 195&deg;F on a frequency controlled by the Surveillance Frequency Control Program (SFCP). The initial frequency will be 24 hours.
In the proposed TS, if the MST Area maximum temperature exceeds 195&deg;F, the Action requires immediate action to verify there is no leakage from the Main Steam Line (MSL) pressure boundary, and periodic verification every 12 hours thereafter. If it cannot be verified that there is no leakage from the MSL pressure boundary or if the periodic verification is not performed, a plant shutdown is required. The plant must be in Mode 3 (Hot Shutdown) within 12 hours and Mode 4 (Cold Shutdown) within 36 hours.
The ambient temperature of the monitored MST area can approach the isolation setpoint for reasons other than actual main steam leaks in the area, such as hot weather, reduced efficiency of turbine building ventilation cooling, non-safety related HVAC transients, or instrument drift. If both MST Area Temperature - High trip systems were to initiate an isolation signal, a full Group 1 isolation and reactor trip would result. Group 1 isolation closes the Main Steam Isolation Valves (MSIVs), resulting in a loss of heat sink, as well as rendering the main feedwater system unavailable for high pressure. Group 1 isolation closes the Main Steam Isolation Valves (MSIVs), resulting in a loss of heat sink, as well as rendering the main feedwater system unavailable for high pressure injection. Such a shutdown would be considered a complicated scram.
The MST Area Temperature - High Function is not assumed to actuate in any accident analysis.
Creating the potential for a complicated reactor scram based on an indication, which may not be indicative of actual MSL pressure boundary leakage, is unnecessary. Replacing this automatic MSIV isolation requirement with a monitoring requirement and a unit shutdown if MSL pressure boundary leakage is detected will eliminate the risk of an unnecessary plant transient while still providing the appropriate remedial actions to ensure the plant is operating safely and within the assumed plant conditions.
2.0 DETAILED DESCRIPTION TS Table 3.3.6.1-1 is modified by the below line within the Table. The below deletion of Trip Function 1.e is the only modification to the TS Table. A full version of the TS Table is within of this LAR. Deleted will replace the line item. 

License Amendment Request Proposed Changes to MSL Tunnel Temperature Isolation Signal Docket No. 50-333 3
FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS PER TRIP SYSTEM CONDITIONS REFERENCED FROM REQUIRED ACTION C.1 SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE
: 1. Main Steam Line Isolation
: e. Main Steam Tunnel Area Temperature 
- High 1,2,3 8
D SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.7 195&deg;F New pages will be inserted to accommodate the new Technical Specification 3.7.8, "Main Steam Tunnel (MST) Area Temperature". The new Limiting Condition for Operation (LCO) 3.7.8 requires the Main Steam Tunnel maximum temperature to be 195&deg;F. The specification is applicable in Modes 1, 2, and 3, the same as existing Function 1.e. A new Surveillance Requirement (SR) 3.7.8.1 will require verification that the Main Steam Tunnel Area temperature is 195&deg;F on a frequency controlled by the Surveillance Frequency Control Program (SFCP).
The initial frequency will be 24 hours. 

==3.0 TECHNICAL EVALUATION==
The main steam line small leak ambient temperature sensors are physically grouped into a series of four sensors per steam line, such that the separation is up to approximately 70 ft between sensors per steam line. The four groups of four sensors monitor the entire length of the four main steam lines from the drywell penetration and inboard MSIVs up to the turbine stop valve inlets.
Two additional temperature sensors are located at the tunnel inlet and outlet to provide an ambient and differential temperature alarm in the event of a leak within the tunnel. One set of four additional temperature sensors are located near the tunnel outlet that provides an ambient temperature alarm only.
The large number of available indications and their dispersed arrangement near the steam lines provide confidence that a significant break would be detected rapidly and accurately in the main steam tunnel.
The safety objective of the steam leak detection system is to detect small steam leaks in selected areas of the plant to preclude further damage to plant equipment and to limit radiation exposures to both plant personnel and the public. In response to a steam leak alarm, operator action was usually prescribed to identify and isolate the cause of the steam leak.
The purpose of the MST Area Temperature isolation function is to provide timely detection and isolation of small Main Steam line leaks prior to catastrophic failure of the piping while maintaining sufficient margin above normal operating temperatures to avoid spurious isolation.
The MST Area Temperature instrumentation is part of the MSIV Group 1 isolation logic and isolates the normally open MSIVs and the normally closed Main Steam line drain valves. 

License Amendment Request Proposed Changes to MSL Tunnel Temperature Isolation Signal Docket No. 50-333 4
The MST Temperature instrumentation and logic is not required to mitigate any design basis event and credit for this isolation instrumentation is not taken in any transient or accident analysis in Updated Final Safety Analysis Report (UFSAR) Chapter 14. Bounding analyses are performed for large breaks, such as Main Steam line breaks that solely credit the automatic Main Steam line high flow isolation. The MST Temperature isolation and reactor vessel low level and low steam pressure isolations provide a diverse isolation function to the credited Main Steam line high flow isolation. This function does not require an automatic isolation of the MSLs on MST Area high temperature to assure plant safety. Given the purpose of the function, the consequences of an automatic reactor scram due to closure of the MSIVs is unwarranted.
As an alternative, the proposed TS 3.7.8 will ensure that a MSL pressure boundary leak in the MST will be promptly detected, and appropriate actions will be taken.
The proposed LCO 3.7.8 requires that the MST area maximum temperature be 195&deg;F. The current TS allowable value ensures a 65-gpm equivalent steam leak during seasonal hot weather conditions and a 100-gpm equivalent steam leak during seasonal cold weather conditions will be detected, when sustained over a period of 30 minutes. Ambient temperature assumptions are a key driver of this sensitivity.
The purpose of this preemptive feature is to detect a steam line leak prior to the flow rate corresponding to a critical crack size which will not propagate into a full pipe rupture for the respective system piping. For JAF the critical crack length for main steam piping, as depicted in UFSAR Figure 4.10-3, is approximately 383 gpm. The corresponding 65 gpm summer and 100 gpm winter threshold is adequate to assure early detection and manual isolation, after condition confirmation, of a main steam line leak within the Main Steam Tunnel with a large amount of margin to the critical crack size. This automatic leak before break detection isolation function is not required to satisfy any design basis event.
The Applicability of LCO 3.7.8 is Modes 1, 2, and 3. In Modes 1, 2, and 3, a Design Basis Accident (DBA) could result in the release of radioactive material into the MST if there is a leak in the MSLs. In Modes 4 and 5, the probability and consequences of a DBA with fission product release into the MST are reduced because of the pressure and temperature limitations in these conditions. Therefore, maintaining MST temperature within limits is not required in Mode 4 or 5.
The proposed Applicability is the same as the current Function 1.e.
The proposed Surveillance Requirement (SR) 3.7.8.1 requires verification that MST Area temperature is 195&deg;F. The Frequency is controlled under the SFCP, and the initial frequency will be every 24 hours. As stated in SR 3.0.1, SRs must be met between performances of the Surveillance. If the MST Area temperature exceeds 195&deg;F, operators will be alerted to take action.
The TS 3.7.8 Actions apply if the MST area temperature is exceeded. It requires immediate action to determine if there is leakage from the MSL pressure boundary.
MST area temperature may be elevated due to reasons other than an MSL pressure boundary leak, such as hot weather, reduced turbine building ventilation airflow or area cooling, and faulty temperature detectors. Verification will determine whether the elevated temperature is due to leakage from the MSL pressure boundary or another reason. Operations personnel are trained to perform the actions required to verify if leakage exists from the MSL pressure boundary, and no additional training or new operator actions will be required to perform the actions of TS 3.7.8. 

License Amendment Request Proposed Changes to MSL Tunnel Temperature Isolation Signal Docket No. 50-333 5
If the elevated temperature is determined to not be due to leakage from the MSL pressure boundary and while MST area temperature exceeds 195&deg;F, the Actions require verification every 12 hours that there is no leakage from the MSL pressure boundary. The area monitored in the MST area has elevated radiation levels and adverse environmental conditions. The 12-hour Completion Time balances the small likelihood of a MSL pressure boundary leak occurring since the last verification against the risks of exposing workers to the radiological and environmental conditions to perform the verification.
If leakage from the MSL pressure boundary is detected or if the periodic verification is not performed, the actions require a plant shutdown. The plant must be brought to least Mode 3 (Hot Shutdown) within 12 hours and Mode 4 (Cold Shutdown) within 36 hours. The proposed times are consistent with the requirements of similar specifications and are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
The following TS functions will continue to provide automatic MSL isolation:
Reactor Vessel Water level - Low, Low, Low - Level 1 Main Steam Line Pressure - Low Main Steam Line Flow - High Condenser Vacuum - Low Removing the automatic isolation function and adding a reactor shutdown requirement on high MST area temperature will have no adverse effect on equipment qualification. Once the 195&#xba;F temperature threshold is entered, procedural guidance will trigger an engineering review of qualified SSCs to evaluate the actual condition and any remedial actions. 

==4.0 REGULATORY EVALUATION==
4.1 Applicable Regulatory Requirements/Criteria The following applicable regulations and regulatory requirements were reviewed in the development of this submittal:
10 CFR 50.36: (1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; and (4) a structure, system, or component which operating experience or probabilistic risk assessment (PRA) has shown to be significant to public health and safety. As a result, TS requirements which satisfy any of the criteria in 10 CFR 50.36 must be retained in the TS.
MSL pressure boundary leakage in the MST Area is monitored to protect the assumptions of the accident dose analysis. Therefore, the requirement to monitor MST maximum area temperature is treated as an operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier and is maintained 

License Amendment Request Proposed Changes to MSL Tunnel Temperature Isolation Signal Docket No. 50-333 6
in the TS per Criterion 2. Revising the requirement from an automatic isolation to manual detection and shutdown does not affect the ability to satisfy Criterion 2.
10 CFR Part 50 Appendix A General Design Criteria (GDC) 30: Components which are part of the Reactor Coolant Pressure Boundary (RCPB) shall be designed, fabricated, erected, and tested to the highest quality standards practical. Means shall be provided for detecting and, to the extent practical, identifying the location of the source of reactor coolant leakage.
Means are provided for detecting reactor coolant leakage. The leak detection system consists of sensors and instruments to detect, annunciate, and, in some cases, isolate the RCPB from potential hazardous leaks before predetermined limits are exceeded. As described in UFSAR Section 4.10.4, small leaks are detected by temperature and pressure changes, increased frequency of sump pump operation, and measurement of airborne radioactivity in the primary containment atmosphere. In addition to these means of detection, large leaks are detected by flow rates in process lines and changes in reactor water level. The allowable leakage rates are based on the predicted and experimentally determined behavior of cracks in pipes, the ability to make up coolant system leakage, the normally expected background leakage due to equipment design, and the detection capability of the various sensors and instruments. The total leakage rate limit is established so that, in the absence of normal ac power concurrent with a loss of feedwater supply, makeup capabilities are provided by the RCIC system. While the leak detection system provides protection from small leaks, the ECCS network provides protection for the complete range of discharges from ruptured pipes. Thus, protection is provided for the full spectrum of possible discharges. The RCPB and the leak detection system meet the requirements of GDC 30.
10 CFR Part 50 Appendix A General Design Criteria (GDC) 54: Piping systems penetrating primary reactor containment shall be provided with leak detection, isolation, and containment having redundancy, reliability, and performance capabilities which reflect the importance to safety of isolating these piping systems.
The JAF design incorporates various and diverse leak detection and containment isolation features consistent with the requirements of GDC 54. It is proposed that the Main Steam Tunnel Area Temperature - High isolation function be removed from the TS for containment isolation instrumentation. Appropriate automatic isolations for MSIVs are still retained consistent with GDC 54 by other diverse leakage detection features.
4.2 Precedents By {{letter dated|date=October 13, 2021|text=letter dated October 13, 2021}}, Southern Nuclear Operating Company (SNC) submitted a license amendment request for Edwin I. Hatch Nuclear Plant Unit Nos. 1 and 2 (Hatch) titled, "Request to Eliminate Automatic Main Steam Line Isolation on High Turbine Building Area Temperature" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21286A595). The amendment was approved on May 20, 2022 (ADAMS Accession No. ML22101A094).
Following the approval of the Hatch amendment, Limerick Generating Station submitted License Amendment Request for Proposed Changes to the Technical Specification Isolation Actuation Instrumentation Tables and New Turbine Enclosure Main Steam Line Tunnel 

License Amendment Request Proposed Changes to MSL Tunnel Temperature Isolation Signal Docket No. 50-333 7
Temperature TS 3/4.7.9 on June 13, 2024. (ADAMS Accession No. ML24165A264). The amendment was approved on July 29, 2024 (ADAMS Accession No. ML24204A071).
The Hatch "Turbine Building Area Temperature - High," served the same purpose as the LGS "Turbine Enclosure Main Steam Line Tunnel Temperature," function. Both functions actuated the MSIVs on high temperature indications around the MSL. Both functions were intended to automatically shut down the plant on small indications of MSL leakage. In both cases, actuation of the function would cause a complicated scram.
JAFs Main Steam Tunnel Area Temperature - High instrumentation also serves the same purpose to isolate the main steam isolation valves automatically upon detection of small leaks below the critical flaw size on the main steam lines. Like both Hatch and Limerick, the isolation response would cause a complicated reactor scram.
Unique to the JAF request, Main Steam Tunnel Temperature - High instrumentation includes the outboard main steam isolation valves themselves, with the temperature instrumentation being distributed along the steam tunnel in four locations, including in the area immediately surrounding the outboard MSIVs. Hatch and Limerick retained separate automatic isolations for the Outboard MSIV Room Temperature - High for Limerick and Main Steam Tunnel Temperature - High for Hatch.
4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF).
The proposed change removes Function 1.e, "Main Steam Tunnel Area Temperature - High,"
and inserts the word "Deleted" in Table 3.3.6.1-1 Primary Containment Isolation Instrumentation, Deletion of Function 1.e does not require modification to any Actions or Surveillance Requirements.
The proposed change adds a new TS 3.7.8, "Main Steam Tunnel (MST) Area Temperature".
The new Limiting Condition for Operation (LCO) 3.7.8 requires the MST Area maximum temperature to be 195&deg;F. The specification is applicable in Modes 1, 2, and 3, the same as existing Function 1.e. Surveillance Requirement (SR) 3.7.8.1 requires verification that the MST Area temperature is 195&deg;F on a frequency controlled by the Surveillance Frequency Control Program (SFCP). The initial frequency will be 24 hours.
In the proposed TS, if the MST Area maximum temperature exceeds 195&deg;F, the Action requires immediate action to verify there is no leakage from the Main Steam Line (MSL) pressure boundary, and periodic verification every 12 hours thereafter. If it cannot be verified that there is no leakage from the MSL pressure boundary or if the periodic verification is not performed, a plant shutdown is required. The plant must be in Mode 3 (Hot Shutdown) within 12 hours and Mode 4 (Cold Shutdown) within 36 hours.
CEG has evaluated the proposed changes, using the criteria in 10 CFR 50.92, "Issuance of amendment," and has determined that the proposed changes do not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration. 

License Amendment Request Proposed Changes to MSL Tunnel Temperature Isolation Signal Docket No. 50-333 8
: 1.
Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed changes do not alter any of the previously evaluated accidents in the UFSAR. The proposed changes do not affect any of the initiators of previously evaluated accidents in a manner that would increase the likelihood of the event. The proposed change also eliminates the automatic Main Steam Isolation Valve (MSIV) isolation function associated with MST Area high temperature from the requirements of the Technical Specifications (TS) and creates TS requirements for MST Area temperature monitoring in a new TS 3.7.8.
Automatic isolation of the MSIVs on MST Area high temperature is not an initiator of any accident previously evaluated. A manual plant shutdown initiated due to MSL leakage in the MST is not an initiator of any accident previously evaluated. There is no credit taken in any licensing basis analysis for MSIV closure on MST Area high temperature, and there are no calculations that credit the subject isolation function as a mitigative feature.
As a result, the likelihood of malfunction of an SSC is not increased. The capability and operation of the mitigation systems are not affected by the proposed changes. Thus, the mitigating systems will continue to be initiated and mitigate the consequences of an accident as assumed in the analysis of accidents previously evaluated.
Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2.
Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed changes will not introduce any new operating modes, safety-related equipment lineups, accident scenarios, system interactions, or failure modes that would create a new or different type of accident. Failure of the system will have the same effect as the present design.
The proposed change also eliminates the automatic MSIV isolation function associated with MST Area high temperature from the requirements of the TS and creates TS requirements for MST Area temperature monitoring in a new TS 3.7.8. Eliminating the automatic isolation of the MSIVs will not create a new or different kind of accident from those previously evaluated as a Main Steam Line Break has been evaluated. Elimination of the automatic isolation function will not create a new failure mechanism as a plant shutdown continues to be required if an MSL leak is detected.
The proposed change from an automatic shutdown to a manual shutdown will not create any credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases. The unlikely failure to manually detect an MSL leak and shutdown the plant and that failure leading to a Main Steam Line Break has already been evaluated and is not a new type of accident. 

License Amendment Request Proposed Changes to MSL Tunnel Temperature Isolation Signal Docket No. 50-333 9
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3.
Do the proposed changes involve a significant reduction in a margin of safety?
Response: No The proposed changes do not affect the accident source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of any accident previously evaluated and are consistent with safety analysis assumptions and resultant consequences. The proposed changes do not impact reactor operating parameters or the functional requirements of the affected instrumentation systems.
These systems will continue to provide the design basis reactor trips and protective system actuations. All design basis events, and the reliance on the reactor trips and protective system actuations will remain unchanged. No controlling numerical values for parameters established in the UFSAR or the license or Safety Limits are affected by the proposed changes.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Based on the above evaluation, CEG concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (c),
and accordingly, a finding of "no significant hazards consideration" is justified.
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 Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or the health and safety of the public. 

==5.0 ENVIRONMENTAL CONSIDERATION==
CEG has determined that the proposed changes 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 changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, in accordance with 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes. 

==6.0 REFERENCES==
: 1.
Edwin I. Hatch Nuclear Plant Unit Nos. 1 and 2, "Request to Eliminate Automatic Main Steam Line Isolation on High Turbine Building Area Temperature" May 20, 2022 (ADAMS Accession No. ML22101A094). 

License Amendment Request Proposed Changes to MSL Tunnel Temperature Isolation Signal Docket No. 50-333 10
: 2.
Limerick Generating Station License Amendment Request for Proposed Changes to the Technical Specification Isolation Actuation Instrumentation Tables and New Turbine Enclosure Main Steam Line Tunnel Temperature TS 3/4.7.9, July 29, 2024 (ADAMS Accession No. ML24204A071). 

ATTACHMENT 2 License Amendment Request James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Markup of Proposed Technical Specification Pages 

==Subject:==
License Amendment Request for Proposed Changes to the Technical Specification Primary Containment Isolation Instrumentation Tables and New Main Steam Tunnel Area Temperature Technical Specification 3.7.8 REVISED TECHNICAL SPECIFICATIONS PAGES 3.3.6.1-6 3.7.8-1 (new) 

Primary Containment Isolation Instrumentation 3.3.6.1 JAFNPP 3.3.6.1-6 Amendment 351 Table 3.3.6.1-1 (page 1 of 6)
Primary Containment Isolation Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQURIED CHANNELS PER TRIP SYSTEM CONDITIONS REFERENCED FROM REQIRED ACTION C.1 SURVEILLANCE REQUIREMENTS ALLOWED VALUE
: 1.
Main Steam Line Isolation a. Reactor Vessel Water Level - Low Low Low (Level 1) 1,2,3 2
D SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.7 18 inches b. Main Steam Line Pressure - Low 1
2 E
SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.7 825 psig c. Main Steam Line Flow - High 1,2,3 2 per MSL D
SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.7 125.9 psid d. Condenser Vacuum - Low 1,
2(a), 3(a) 2 D
SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.7 8 inches Hg vacuum e. Main Steam Tunnel Area Temperature - High 1,2,3 8
D SR 3.3.6.1.1 SR 3.3.6.1.2 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.7 195&deg;F f. Main Steam Line Radiation - High 1,2,3 2
F SR 3.3.6.1.1 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7 3 times Normal Full Power 

===Background===
(continued)
(a) With any turbine stop valve not closed.
(b) Not used. 

Deleted

Main Steam Tunnel (MST) Area Temperature 3.7.8 JAFNPP 3.7.8-1 Amendment 3.7 PLANT SYSTEMS 3.7.8 Main Steam Tunnel (MST) Area Temperature LCO 3.7.8 The MST Area temperature shall be 195&deg;F.
APPLICABILITY:
MODES 1, 2, and 3.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
MST area temperature not within limit.
A.1 Verify there is no leakage from the Main Steam Line pressure boundary.
Immediately AND Once per 12 hours tthereafter B.
Required Action and associated Completion TTime of Condition A not met.
B.1 Be in MODE 3.
AND B.2 Be in MODE 4.
12 hours 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 Verify MST area temperature is 195&deg;F.
In accordance with the Surveillance Frequency Control Program Entirely new page

ATTACHMENT 3 License Amendment Request James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Markup of Proposed Technical Specification Bases Pages 

==Subject:==
License Amendment Request for Proposed Changes to the Technical Specification Primary Containment Isolation Instrumentation Tables and New Main Steam Tunnel Area Temperature Technical Specification 3.7.8 REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3.3.6.1-1 B 3.3.6.1-2 B 3.3.6.1-9 B 3.3.6.1-10 B 3.3.6.1-24 B 3.7.8-1 B 3.7.8-2 B 3.7.8-3 

Primary Containment Isolation Instrumentation B 3.3.6.1 B 3.3 INSTRUMENTATION B 3.3.6.1 Primary Containment Isolation Instrumentation BASES JAFNPP B 3.3.6.1-1 Revision 57 BACKGROUND The primary containment isolation instrumentation automatically iinitiates closure of appropriate primary containment isolation valves (PCIVs). The function of the PCIVs, in combination with other accident m
mitigation systems, is to limit fission product release during and following postulated Design Basis Accidents (DBAs). Primary containment isolation within the time limits specified for those iisolation valves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a DBA.
The isolation instrumentation includes the sensors, logic circuits, relays, and switches that are necessary to cause initiation of primary containment and reactor coolant pressure boundary (RCPB) isolation..
Most channels include electronic equipment (e.g., trip units) that ccompares measured input signals with pre-established setpoints.
When the setpoint is exceeded, the channel output relay actuates, wwhich then outputs a primary containment isolation signal to the isolation logic. Functional diversity is provided by monitoring a wide range of independent parameters. The input parameters to the isolation logics are (a) reactor vessel water level, (b) main steam line
((MSL) pressure, (c) MSL flow, (d) condenser vacuum, (e) main steam tunnel area temperatures deleted, (f) main steam line radiation, (g) drywell pressure, (h) containment radiation, (i) high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) ssteam line flow, (j) HPCI and RCIC steam line pressure, (k) HPCI and RCIC turbine exhaust diaphragm pressure, (l) HPCI and RCIC area temperatures, (m) reactor water cleanup (RWCU) area temperature, (n) Standby Liquid Control (SLC) System initiation, and (o) reactor pressure. Redundant sensor input signals from each parameter are provided for initiation of isolation. The only exception is SLC System initiation.
Primary containment isolation instrumentation has inputs to the trip logic of the isolation functions listed below.
: 1. Main Steam Line Isolation Most MSL Isolation Functions receive inputs from four channels. The outputs from these channels are combined in a one-out-of-two taken twice logic to initiate isolation of all main steam isolation valves (continued) 

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES JAFNPP B 3.3.6.1-2 Revision 57
: 1. Main Steam Line Isolation (continued)
(MSIVs). The outputs from the same channels are arranged into two two-out-of-two logic trip systems to isolate all MSL drain valves. The M
MSL drain line has two isolation valves with one two-out-of-two logic system associated with each valve.
The exceptions to this arrangement are the Main Steam Line Flow High, Main Steam Tunnel Temperature High and the Main Steam Line Radiation High Functions. The Main Steam Line Flow High Function uses 16 flow channels, four for each steam line. One channel from each steam line inputs to one of the four trip channels.
Two trip channels make up each trip system and both trip systems must trip to cause an MSL isolation. Each trip channel has four inputs
((one per MSL), any one of which will trip the trip channel. The trip channels are arranged in a one-out-of-two taken twice logic. This is effectively a one-out-of-eight taken twice logic arrangement to initiate isolation of the MSIVs. Similarly, the 16 flow channels are connected into two two-out-of-two logic trip systems (effectively, two one-out-of-four twice logic), with each trip system isolating one of the two MSL drain valves on the associated steam line. The Main Steam Tunnel Temperature High Function receives input from 16 channels.
The logic is arranged similar to the Main Steam Line Flow High Function. The Main Steam Line Radiation High Function receives inputs from four channels. The outputs from the channels are arranged into two two-out-of-two logic trip systems and isolates the MSL drain valves. This Function does not provide an MSIV isolation ssignal. Each trip system is associated with one MSL drain valve with a ttwo-out-of-two logic.
: 2. Primary Containment Isolation The Reactor Vessel Water Level Low (Level 3) and Drywell Pressure High Primary Containment Isolation Functions (Functions 2.a and 2.b) receive inputs from four channels. Normally the outputs from these channels are arranged into two two-out-of-two logic trip systems. One trip system initiates isolation of all inboard primary containment isolation valves, while the other trip system initiates isolation of all outboard primary containment isolation valves. Each logic closes one of the two valves on each 2. Primary Containment Isolation penetration, so that operation of either logic isolates the penetration. The exception to this arrangement for the Reactor Vessel W
Water Level Low (Level 3) and Drywell Pressure High Functions (Functions 2.d and 2.g) are with certain penetration flow paths (i.e.,
BACKGROUND (continued) 

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES JAFNPP B 3.3.6.1-9 Revision 57 1.c.. Main Steam Line Flow High (continued) enough to permit early detection of a gross steam line break.
This Function isolates the MSIVs and MSL drain valves.
1.d. Condenser Vacuum Low The Condenser Vacuum Low Function is provided to prevent overpressurization of the main condenser in the event of a loss of the m
main condenser vacuum. Since the integrity of the condenser is an assumption in offsite dose calculations, the Condenser Vacuum Low Function is assumed to be OPERABLE and capable of initiating closure of the MSIVs. The closure of the MSIVs is initiated to prevent the addition of steam that would lead to additional condenser ppressurization and possible rupture of the diaphragm installed to protect the turbine exhaust hood, thereby preventing a potential radiation leakage path following an accident.
Condenser vacuum pressure signals are derived from four pressure transmitters that sense the pressure in the condenser. Four channels oof Condenser Vacuum Low Function are available and are required to be OPERABLE to ensure that no single instrument failure can ppreclude the isolation, function.
The Allowable Value is chosen to prevent damage to the condenser ddue to pressurization, thereby ensuring its integrity for offsite dose analysis. As noted (footnote (a) to Table 3.3.6.1-1), the channels are not required to be OPERABLE in MODES 2 and 3 when all turbine stop vvalves (TSVs) are closed, since the potential for condenser overpressurization is minimized. The Function is automatically bbypassed when the reactor mode switch is not in the run position and when all TSVs are closed.
This Function isolates the MSIVs and MSL drain valves.
1.e. Deleted Main Steam Tunnel Area Temperature High Main Steam Tunnel Area temperature is provided to detect a break in a main steam line and provides diversity to the high flow instrumentation. High temperature in the main steam tunnel outside the primary containment could indicate a break in a main steam line..
The automatic closure of the MSIVs and MSL drains, prevents excessive loss of reactor coolant and the release of significant amounts of radioactive material from the reactor coolant pressure boundary. The isolation occurs when a very small leak has occurred. If the small leak is allowed to continue without isolation, offsite dose 1.e. Main Steam Tunnel Area Temperature High (continued)
APPLICABLE SAFETY ANALYSIS, LCO, and APPLICABILITY (continued) 

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES JAFNPP B 3.3.6.1-10 Revision 57 limits may be reached.. However, credit for these instruments is not taken in any transient or accident analysis in the UFSAR, since bounding analyses are performed for large breaks, such as MSLBs.
Main Steam Tunnel Area temperature signals are initiated from resistance temperature detectors (RTDs) located in the area being monitored. Sixteen channels of Main Steam Tunnel Temperature High Function are available and are required to be OPERABLE to ensure that no single instrument failure can preclude the isolation function.
The Allowable Value is chosen high enough above the temperature expected during power operations to avoid spurious isolation, yet low enough to provide early indication of a steam line break.
This Function isolates the MSIVs and MSL drain valves.
1.f. Main Steam Line Radiation High The Main Steam Line Radiation High isolation signal has been removed from the MSIV isolation logic circuitry (Ref. 1); however, this isolation Function has been retained for the MSL drains valves (and oother valves discussed under Function 2.f) to ensure that the assumptions utilized to determine that acceptable offsite doses resulting from a control rod drop accident (CRDA) are maintained.
Main Steam Line Radiation High signals are generated from four radiation elements and associated monitors, which are located near the main steam lines in the steam tunnel. Four instrumentation channels of the Main Steam Line Radiation High Function are available and required to be OPERABLE to ensure that no single iinstrument failure can preclude the isolation function.
The Allowable Value was selected to be low enough that a high rradiation trip results from the fission products released in the CRDA.
In addition, the setting is adjusted high enough above the background radiation level in the vicinity of the main steam lines so that spurious trips are avoided at rated power.
The Analytical Limit of 10,000 mr/hr was established by specific analysis to support use of a single trip setpoint for the Main Steam Line Radiation - High isolation signal. In accordance with the analysis.
aany setpoint less than the Analytical Limit provides assurance that the accident analysis remains bounding. This trip setpoint is dependent on general area background radiation levels near the APPLICABLE SAFETY ANALYSIS, LCO, and APPLICABILITY (continued) 

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES JAFNPP B 3.3.6.1-24 Revision 57 A.1 (continued)
(or the associated trip system in trip), such that both trip systems will generate a trip signal from the given Function on a valid signal. The oother isolation functions are considered to be maintaining isolation capability when sufficient channels are OPERABLE or in trip, such that oone trip system will generate a trip signal from the given Function on a valid signal. This ensures that at least one of the PCIVs in the associated penetration flow path can receive an isolation signal from tthe given Function. For Functions 1.a, 1.b, and 1.d (associated with MSIV isolation), this would require both trip systems to have one cchannel OPERABLE or in trip. For Function 1.c (associated with MSIV isolation), this would require both trip systems to have one channel, associated with each MSL, OPERABLE or in trip.
For Function 1.e, four areas are monitored by four channels (e.g.,
different locations within the main steam tunnel area). Therefore, this would require both trip systems to have one channel per location OPERABLE or in trip (associated with MSIV isolation). For Functions 1.a, 1.b, 1.d, and 1.f (associated with MSL drain isolation) this would require one trip system to have two channels, each OPERABLE or in trip. For Function 1.c (associated with MSL drain isolation) this will require one trip system to have two channels, associated with each MSL, each OPERABLE or in trip. For Function 1.e this would require one trip system to have two channels, associated with each main steam tunnel area, each to be OPERABLE or in trip. For Functions 2.d and 2.g, as noted by footnote (c) to Table 3.3.6.1-1, there is only one trip system provided for each associated penetration. For these penetrations (i.e., hydrogen/oxygen sample and return, and ggaseous/particulate sample supply and return), this will require both channels to be OPERABLE or in trip in order to close at least one valve. For Functions 2.a, 2.b, 2.e, 2.f, 3.b, 3.c, 4.b, 4.c, 5.e, 5.f, and 6.b, this would require one trip system to have two channels, each OPERABLE or in trip. For Functions 2.c, 3.a, 3.d, 3.e, 3.f, 3.g, 3.h, 3.i, 4.a, 4.d, 4.e, 5.a, 5.c, and 6.a, this would require one trip system to have one channel OPERABLE or in trip. For Functions 3.j, 4.f, and 5.b eeach Function consists of channels that monitor two different locations. Therefore, this would require one channel per location to be OOPERABLE or in trip (the channels are not required to be in the same trip system). For Function 5.d, this would require that with the SLC initiation switch in start system A or B the associated valve will close.
For Function 7.a and 7.b the logic is arranged in one trip system, therefore this would require both channels to be OPERABLE or in trip, (continued)
ACTIONS 

Main Steam Tunnel (MST) Area Temperature B 3.7.8 B 3.7 PLANT SYSTEMS B 3.7.8 Main Steam Tunnel (MST) Area Temperature BASES JAFNPP B 3.7.8-1 Revision BACKGROUND Main Steam Line (MSL) leakage is limited to ensure that the accident analyses demonstrate that the offsite and control room dose limits are met. For purposes of this Technical Specification, MSL pressure boundary leakage is defined as leakage from any of the four MSLs or any unisolable branch off the MSL in the area from the Main Steam Isolation Valves (MSIVs) up to the steam chests. Direct detection of small amounts of MSL leakage is not practical, so monitoring the area temperatures near the MSLs is used as a surrogate indication of an MSL leak.
Main Steam Tunnel (MST) Area temperature is monitored to detect a break in a MSL and provide diversity to the high flow instrumentation.
High temperature in the main steam tunnel outside the primary containment could indicate a break in a MSL. MST area temperature may be elevated due to reasons other than an MSL pressure boundary leak, such as hot weather, reduced turbine building ventilation airflow or area cooling and faulty temperature detectors.
APPLICABLE SAFETY ANALYSIS MST Area temperature is provided to detect a break in a MSL and provides diversity to the MSL high flow, low Reactor Pressure Vessel (RPV) pressure, and low RPV water level instrumentation.
High temperature in the MST outside the primary containment could indicate a flaw or break in a MSL. If the small leak is allowed to continue without isolation, offsite dose limits may be reached.
However, credit for these instruments is not taken in any transient or accident analysis in the UFSAR, since bounding analyses are performed for large breaks, such as MSLBs.
The Allowable Value is chosen low enough to provide early indication of a steam line break in the main steam lines.
MST Area temperature satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO The MST Area Temperature is required to be 195&deg;F to ensure MSL pressure boundary leakage is identified and a shutdown is commenced if MSL pressure boundary leakage exists. 

Main Steam Tunnel (MST) Area Temperature B 3.7.8 BASES JAFNPP B 3.7.8-2 Revision APPLICABILITY The MST Area Temperature is required to be 195&deg;F in MODES 1, 2, and 3. In Modes 1, 2, and 3, a Design Basis Accident (DBA) could result in the release of radioactive material into the MST if there is a leak in the MSLs. In MODES 4 and 5 the probability and consequences of a DBA with fission product release into the MST are reduced because of the pressure and temperature limitations in these conditions.
ACTIONS A.1 If the MST Area Temperature is not 195&deg;F immediate action must be taken to verify there is no leakage from the MSL pressure boundary.
With MST area temperature exceeding the 195&deg;F, following the immediate verification that there is no leakage from the MSL pressure boundary it must be verified once per 12 hours thereafter.
Evidence of a MSL leak includes, but is not limited to:
x An unexpected sudden rise in tunnel temperature, main steam line radiation monitor readings, steam tunnel sump pumpouts, or turbine building ventilation radiation monitors x An unexpected decrease in plant electrical output, or x Visual and sound indications of a steam leak.
MSL pressure boundary leakage refers to a fault in a MSL component body or pipe wall. Leakage past gaskets, packing, and seals is not pressure boundary leakage.
This action requires understanding the cause of the elevated temperature, and assurance that the MSL pressure boundary remains intact.
B.1 and B.2 If any Required Action and associated Completion Time is not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 12 hours and to MODE 4 within 36 hours.
The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions without challenging plant safety systems.
SURVEILLANCE REQUIREMENTS SR 3.7.8.1 Verification that the maximum area temperature is 195&deg;F ensures there is no MSL leak in the MST area. In order to ensure timely (continued) 

Main Steam Tunnel (MST) Area Temperature B 3.7.8 BASES JAFNPP B 3.7.8-3 Revision SURVEILLANCE REQUIREMENTS (continued) detection of an MSL leak, the MST area must be monitored.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES
: 1. UFSAR, Section 14.6.1.5
: 2. NRC letter dated [Month XX, 2026], Issuance of Amendment [XX] to the Facility Operating License DPR-59 for James A. FitzPatrick Nuclear Power Plant.}}