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{{#Wiki_filter:Exelon Nuclear www.exe1oncorp.com 200 Exelon Way Nuclear Kennett Square, PA 19348 10 CFR 50.90 June 27,2007 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos.
{{#Wiki_filter:Exelon Nuclear                     www.exe1oncorp.com 200 Exelon Way                                                                         Nuclear Kennett Square, PA 19348 10 CFR 50.90 June 27,2007 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket N o . c i a n c L 5 0 - 3 5 3
NPF-39 and NPF-85 NRC Docket No.ciancL50-353


==SUBJECT:==
==SUBJECT:==
License Amendment Request Proposed Changes to Accident Monitoring Instrumentation Technical Specifications Pursuant to 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively. The proposed changes relocate the operability and surveillance requirements for the drywell air temperature and suppression chamber air temperature instrumentation from LGS TS Section 3.3.7.5, "Accident Monitoring Instrumentation," to the LGS Technical Requirements Manual (TRM). The proposed changes conform to 10 CFR 50.36 for the contents of TS, and to the improved Standard Technical Specifications approved by the NRC in NUREG-1433, "Standard Technical Specifications - General Electric Plants, BWRI4." A similar change, to relocate the operability and surveillance requirements for the safetyhelief valve position indication instrumentation from TS Section 3.3.7.5 to the TRM, was approved by the NRC by issuance of Amendment Nos.
License Amendment Request Proposed Changes to Accident Monitoring Instrumentation Technical Specifications Pursuant to 10 CFR 50.90, "Application for amendment of license or construction permit,"
179 and 141 for LGS, Units 1 and 2, respectively, by letter dated September 27, 2005.
Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively.
Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 1 OCFR 50.92. This amendment request contains no regulatory commitments.
The proposed changes relocate the operability and surveillance requirements for the drywell air temperature and suppression chamber air temperature instrumentation from LGS TS Section 3.3.7.5, "Accident Monitoring Instrumentation," to the LGS Technical Requirements Manual (TRM).
Exelon requests approval of the proposed amendment by June 27,2008. Upon NRC approval, the amendment shall be implemented within 60 days of issuance. These proposed changes have been reviewed by the Plant Operations Review Committee.
The proposed changes conform to 10 CFR 50.36 for the contents of TS, and to the improved Standard Technical Specifications approved by the NRC in NUREG-1433, "Standard Technical Specifications - General Electric Plants, BWRI4." A similar change, to relocate the operability and surveillance requirements for the safetyhelief valve position indication instrumentation from TS Section 3.3.7.5 to the TRM, was approved by the NRC by issuance of Amendment Nos. 179 and 141 for LGS, Units 1 and 2, respectively, by letter dated September 27, 2005.
Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10CFR 50.92.
This amendment request contains no regulatory commitments.
Exelon requests approval of the proposed amendment by June 27,2008. Upon NRC approval, the amendment shall be implemented within 60 days of issuance.
These proposed changes have been reviewed by the Plant Operations Review Committee.
 
License Amendment Request Changes to Accident Monitoring Instrumentation Docket Nos. 50-352 and 50-353 June 27,2007 Page 2 We are notifying the State of Pennsylvania of this application for changes to the Technical Specifications by transmitting a copy of this letter and its attachments to the designated State Official.
License Amendment Request Changes to Accident Monitoring Instrumentation Docket Nos. 50-352 and 50-353 June 27,2007 Page 2 We are notifying the State of Pennsylvania of this application for changes to the Technical Specifications by transmitting a copy of this letter and its attachments to the designated State Official.
If you have any questions or require additional information, please contact Glenn Stewart at 61 0-765-5529.
If you have any questions or require additional information, please contact Glenn Stewart at 610-765-5529.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 27th day of June, 2007.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 27th day of June, 2007.
Respectfully, Pamela B. &wan Director - Licensing  
Respectfully, Pamela B. &wan Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments:       1. Evaluation of Proposed Changes
& Regulatory Affairs Exelon Generation Company, LLC Attachments:
: 2. Markup of Proposed Technical Specifications Pages cc:     Regional Administrator - NRC Region I                                     W/ attachments NRC Senior Resident Inspector - Limerick Generating Station I1 NRC Project Manager, NRR - Limerick Generating Station 11 Director, Bureau of Radiation Protection - Pennsylvania Department I1 of Environmental Protection
: 1. Evaluation of Proposed Changes
 
: 2. Markup of Proposed Technical Specifications Pages cc: Regional Administrator - NRC Region I W/ attachments NRC Senior Resident Inspector - Limerick Generating Station I1 NRC Project Manager, NRR - Limerick Generating Station 11 Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection I1 ATTACHMENT 1 License Amendment Request Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 EVALUATION OF PROPOSED CHANGES  
ATTACHMENT 1 License Amendment Request Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 EVALUATION OF PROPOSED CHANGES


==Subject:==
==Subject:==
Proposed Changes to Acci dent Monitoring Instrumentation Technical Specifications  
Proposed Changes to Accident Monitoring Instrumentation Technical Specifications
 
==1.0 DESCRIPTION==
 
==2.0 PROPOSED CHANGE==
S
 
==3.0 BACKGROUND==
 
==4.0 TECHNICAL ANALYSIS==
 
==5.0 REGULATORY ANALYSIS==
 
==6.0 ENVIRONMENTAL CONSIDERATION==
 
==7.0 REFERENCES==
 
License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation  Page 1 of 8


Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes
==1.0  DESCRIPTION==


==1.0 DESCRIPTION==
==2.0 PROPOSED CHANGE==
S


Pursuant to 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon
==3.0  BACKGROUND==


Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS),
==4.0  TECHNICAL ANALYSIS==
Appendix A of Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively.  


The proposed changes relocate the operability and surveillance requirements for the drywell air
==5.0  REGULATORY ANALYSIS==


temperature and suppression chamber air temper ature instrumentation from the Accident Monitoring Instrumentation section of TS, i.e., from LGS TS 3.3.7.5 and 4.3.7.5 to the LGS
==6.0  ENVIRONMENTAL CONSIDERATION==


Technical Requirements Manual (TRM). The TRM is incorporated by reference into the LGS Updated Final Safety Analysis Report (UFSAR) and is subject to the controls of 10 CFR 50.59.   
==7.0 REFERENCES==


Accordingly, any future changes to the drywell air temperature and suppression chamber air
License Amendment Request                                                              Attachment 1 Changes to Accident Monitoring Instrumentation                                            Page 1 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes


temperature instrumentation operability and surveillance requirements will be performed pursuant to 10 CFR 50.59.  
==1.0      DESCRIPTION==


The proposed changes conform to 10 CFR 50.36 (Reference 1) for the contents of TS, and to  
Pursuant to 10 CFR 50.90, Application for amendment of license or construction permit, Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS),
Appendix A of Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively.
The proposed changes relocate the operability and surveillance requirements for the drywell air temperature and suppression chamber air temperature instrumentation from the Accident Monitoring Instrumentation section of TS, i.e., from LGS TS 3.3.7.5 and 4.3.7.5 to the LGS Technical Requirements Manual (TRM). The TRM is incorporated by reference into the LGS Updated Final Safety Analysis Report (UFSAR) and is subject to the controls of 10 CFR 50.59.
Accordingly, any future changes to the drywell air temperature and suppression chamber air temperature instrumentation operability and surveillance requirements will be performed pursuant to 10 CFR 50.59.
The proposed changes conform to 10 CFR 50.36 (Reference 1) for the contents of TS, and to the improved Standard Technical Specifications approved by the NRC in NUREG-1433, Standard Technical Specifications - General Electric Plants, BWR/4 (Reference 2). A similar change, to relocate the operability and surveillance requirements for the safety/relief valve position indication instrumentation from TS Section 3.3.7.5 to the TRM, was approved by the NRC by issuance of Amendment Nos. 179 and 141 for LGS, Units 1 and 2, respectively (Reference 3).


the improved Standard Technical Specifications approved by the NRC in NUREG-1433, "Standard Technical Specifications - General Electric Plants, BWR/4" (Reference 2). A similar
==2.0     PROPOSED CHANGE==
 
change, to relocate the operability and surveillance requirements for the safety/relief valve
 
position indication instrumentation from TS Section 3.3.7.5 to the TRM, was approved by the
 
NRC by issuance of Amendment Nos. 179 and 141 for LGS, Units 1 and 2, respectively (Reference 3).
 
==2.0 PROPOSED CHANGE==
S The changes requested by this amendment application are described below.
S The changes requested by this amendment application are described below.
: 1. Delete Item 5, "Suppression Chamber Air Temperature," from TS Table 3.3.7.5-1, "Accident Monitoring Instrumentation," on TS page 3/4 3-85. This table identifies the operability  
: 1. Delete Item 5, Suppression Chamber Air Temperature, from TS Table 3.3.7.5-1, "Accident Monitoring Instrumentation, on TS page 3/4 3-85. This table identifies the operability requirements for this instrumentation.
 
: 2. Delete Item 7, Drywell Air Temperature, from TS Table 3.3.7.5-1, "Accident Monitoring Instrumentation, on TS page 3/4 3-85. This table identifies the operability requirements for this instrumentation.
requirements for this instrumentation.
: 3. Delete 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. This table identifies the surveillance requirements for this instrumentation, i.e., a channel check and channel calibration are specified. The frequency for performing these surveillance requirements is specified in the LGS Surveillance Frequency Control Program (SFCP), which will also be revised to delete the associated surveillance frequencies from the SFCP upon implementation of the approved amendment. The surveillance requirements from TS and the frequency for performing the surveillance requirements from the SFCP will be relocated to the LGS TRM.
: 2. Delete Item 7, "Drywell Air Temperature," from TS Table 3.3.7.5-1, "Accident Monitoring Instrumentation," on TS page 3/4 3-85. This table identifies the operability requirements for  
 
this instrumentation.
: 3. Delete 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. This table  
 
identifies the surveillance requirements for this instrumentation, i.e., a channel check and  
 
channel calibration are specified. The frequency for performing these surveillance  
 
requirements is specified in the LGS Surve illance Frequency Control Program (SFCP), which will also be revised to delete the associated surveillance frequencies from the SFCP upon  
 
implementation of the approved amendment.
The surveillance requirements from TS and the frequency for performing the surveillance requirements from the SFCP will be relocated  
 
to the LGS TRM.
 
License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation  Page 2 of 8
 
Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes
: 4. Delete 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. This table identifies the
 
surveillance requirements for this instrumentation, i.e., a channel check and channel
 
calibration are specified. The frequency for performing these surveillance requirements is
 
specified in the LGS SFCP, which will also be revised to delete the associated surveillance
 
frequencies from the SFCP upon implement ation of the approved amendment. The surveillance requirements from TS and t he frequency for performing the surveillance requirements from the SFCP will be relocated to the LGS TRM.
 
Prior to implementation of the amendment, oper ability and surveillance requirements for the drywell air temperature and suppression chamber air temperature instrumentation will be incorporated into the LGS TRM. The operability requirements will identify compensatory
 
measures and completion times for these instruments. Any subsequent changes to the TRM
 
requirements will be performed in accordance with 10 CFR 50.59.
 
There are no changes to the TS Bases section proposed by this amendment application since
 
the drywell air temperature and suppression cham ber air temperature instrumentation is not specifically identified in the TS Bases. 
 
==3.0 BACKGROUND==
 
The NRC provided guidance for the contents of TS in its "Final Policy Statement on Technical
 
Specifications Improvements for Nuclear Po wer Reactors" (58 FR 39132, July 22, 1993; Reference 4). In particular, the NRC indicated that certain items could be relocated from the TS
 
to licensee-controlled documents. The Final Policy Statement identified future criteria to be used
 
in determining whether particular safety functions are required to be included in the TS, as
 
follows:  (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; (4) a structure, system, or component which operating experience or
 
probabilistic safety assessment has shown to be significant to public health and safety. The
 
NRC adopted amendments to 10 CFR 50.36 (60 FR 36953, July 19, 1995; Reference 5) to
 
codify and incorporate these criteria. 
 
The NRC's policy statement provides that those existing TS requirements which do not satisfy
 
these four specified criteria may be relocated to licensee-controlled documents, such that future
 
changes could be made to these provisions pursuant to 10 CFR 50.59. Subsequently, the
 
nuclear steam supply system owners' gr oups and the NRC staff developed improved standard technical specifications (STS) that would establish models of the Commission's policy for each
 
primary reactor type. The NRC issued the improved STS for General Electric BWR/4 plants as
 
NUREG-1433, which was developed utilizing the guidance and criteria in the Commission's
 
policy statement.
License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation  Page 3 of 8
 
Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes
 
==4.0 TECHNICAL ANALYSIS==
 
The proposed license amendment relocates the drywell air temperature and suppression
 
chamber air temperature instrumentation operab ility and surveillance requirements from the LGS TS to the LGS TRM. The TRM is referenced in the LGS UFSAR and is subject to the controls of
 
10 CFR 50.59. The TRM has been used to capture and control other requirements associated
 
with previous LGS license amendments.
 
As discussed in the Background section above, an NRC policy statement concluded that those
 
existing TS requirements which do not satisfy the screening criteria specified in 10 CFR 50.36
 
may be deleted from the TS, and the requirements established in licensee-controlled documents
 
that are subject to the controls of 10 CFR 50.59. The NRC position on application of the
 
screening criteria to accident monitoring instrumentation is documented in correspondence
 
dated May 9, 1988, T. E. Murley (NRC) to R. F. Janecek (BWR Owners' Group) (Reference 6). 
 
The NRC position is that Regulatory Guide 1.97 (Reference 7), Type A, and Category 1, accident monitoring instrumentation should be incorporated into the plant's TS. The
 
requirements for those instruments not meeting these criteria may be removed from the TS and established in a licensee-controlled document subject to the controls of 10 CFR 50.59. 
 
Regulatory Guide 1.97, Revision 2, defines Type A instruments as those that monitor primary
 
information required to permit the control room operator to take specific manually controlled
 
actions for which no automatic control is provi ded and that are required for safety systems to accomplish their safety functions for design basis accident events. Category 1 instruments are
 
designed for full qualification, redundancy, continuous real-time display, and onsite (standby)
 
power.
 
Regulatory Guide 1.97, Revision 2, designates drywell air temperature instrumentation as Type
 
D, Category 2, instrumentation. Type D instruments provide information to indicate the operation
 
of individual safety systems and other systems im portant to safety. Category 2 instruments are designed to less stringent qualifications that do not require seismic qualification, redundancy, or
 
continuous display, and require only a high reliability power source (not necessarily standby
 
power). From a plant-specific perspective, LGS UFSAR Section 7.5 and UFSAR Table 7.5-3
 
also identify the drywell air temperature instrumentation as Type D, Category 2. Relocating
 
drywell air temperature instrumentation from t he TS to a licensee-controlled document conforms with this NRC position on application of the screening criteria to accident monitoring
 
instrumentation.
 
Regulatory Guide 1.97, Revision 2, does not include suppression chamber air temperature as an
 
accident monitoring variable. Likewise, the LGS UFSAR does not specifically identify
 
suppression chamber air temperature by itself as a Regulatory Guide 1.97 variable. However, LGS UFSAR Section 7.5 does describe the use of suppression chamber air temperature for
 
monitoring the effectiveness of suppression chamber spray flow (a Type D, Category 2 variable).
 
Relocating suppression chamber air temperatur e instrumentation from the TS to a licensee-controlled document conforms with this NRC position on application of the screening criteria to
 
accident monitoring instrumentation.
 
License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation  Page 4 of 8
 
Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes
 
NUREG-1433 identifies improved TS that were developed based on the screening criteria in the "Final Commission Policy Statement on Technical Specifications Improvement for Nuclear Power
 
Reactors," that were subsequently codified in 10 CFR 50.36. According to NUREG-1433, accident monitoring instrumentation that satisfies the definition of Type A in Regulatory Guide
 
1.97 meets Criterion 3 of 10 CFR 50.36(c)(2)(ii). Also, Category I, non-Type A instrumentation is
 
retained in TS because they are intended to assist operators in minimizing the consequences of
 
accidents. Therefore, Category I, non-Type A variables are important for reducing public risk.
 
However, as stated previously, the LGS UFSAR indicates that the drywell air temperature
 
instrumentation is Type D, Category 2 and suppression chamber air temperature is used for
 
monitoring the effectiveness of suppression chamber spray flow (a Type D, Category 2 variable).
 
An assessment of the subject accident monitoring instrumentation against the four criterion of 10
 
CFR 50.36 is provided below.
 
Criterion 1: The drywell air temperature and suppression chamber air temperature
 
instrumentation does not provide the primary information used to detect or indicate a significant
 
abnormal degradation of the reactor coolant pressure boundary considered by Criterion 1. This
 
is consistent with the Commission's Final Policy Statement which indicated that the first criterion
 
was intended to assure that TS controlled those instruments specifically installed to detect
 
reactor coolant leakage. 
 
Criterion 2: The Commission's Final Policy Statement indicates that the basic concept in
 
adequate protection of the public health and safety is that the plant be operated within the
 
bounds of the initial conditions assumed in the existing design basis accident and transient
 
analyses, and that the plant will be operated to preclude unanalyzed transients and accidents. 
 
Therefore, Criterion 2 applies to process variables that are parameters for which specific values
 
or ranges of values have been chosen as reference bounds in the design basis accident or
 
transient analyses, and which are monitored and controlled during normal power operation such
 
that process values remain within the analysis bounds. According to Regulatory Guide 1.97, Revision 2, accident monitoring instrumentation is provided to monitor plant variables and
 
systems during and following design basis accidents or transients. Therefore, Criterion 2 does
 
not apply to accident monitoring instrumentation since accident monitoring instrumentation
 
provides indication of plant variables required by operators during accident conditions to take
 
preplanned manual actions to accomplish safety functions rather than instrumentation that
 
provides indication of process variables that are monitored and controlled by operators during
 
normal plant operations to ensure that the initial conditions for accident analyses are met. As
 
such, the drywell air temperature and suppressi on chamber air temperature instrumentation does not provide the primary information used to monitor process variables, design features or
 
operating restrictions that are an initial condition of a design basis accident or transient analysis
 
considered in Criterion 2. 
 
Criterion 3: Drywell air temperature and suppre ssion chamber air temperature instrumentation does not initiate any automatic safety function. Drywell air temperature and suppression
 
chamber air temperature instrumentation is not used as the primary information required to permit operators to take specific manually controlled actions for which no automatic control is
 
provided, and that are required for safety systems to accomplish their safety functions for design License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation  Page 5 of 8
 
Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes
 
basis accident events. The drywell air temperature indication does indicate the performance of safety systems and other systems important to safety. As such, the drywell air temperature instrumentation is considered Type D, Category 2 (refer to Table 7.5-3 of the LGS UFSAR). 
 
Suppression chamber air temperature is used fo r monitoring the effectiveness of suppression chamber spray flow (a Type D, Category 2 variable). Hence, drywell air temperature and
 
suppression chamber air temperature instrument ation is not part of the primary success path used to mitigate a design basis accident or transient involving a failure of or challenge to the
 
integrity of a fission product barrier considered in Criterion 3.
 
Criterion 4: The loss of the subject accident monitoring instrumentation has negligible effect on
 
the probabilistic safety assessment, and has not been shown to be significant to public health
 
and safety as considered in Criterion 4.
 
Consequently, the drywell air temperature and suppression chamber air temperature instrumentation does not meet any of the screening criteria contained in the Commission's Final
 
Policy Statement and 10 CFR 50.36. This conclusion is supported by the NRC screening criteria
 
for accident monitoring instrumentation required to be in TS as documented in Reference 6 and
 
NUREG-1433 which indicate that only Regulatory Guide 1.97, Type A and Category 1, non-Type
 
A instrumentation as defined by plant-specific analyses are required to be listed in the Accident
 
Monitoring Instrumentation section of TS. As indicated previously, LGS UFSAR Section 7.5 designates the drywell air temperature and suppression chamber air temperature
 
instrumentation as other than Type A or Category 1, non-Type A instrumentation. Accordingly, the drywell air temperature and suppression chamber air temperature instrumentation requirements can be established in a licensee-controlled document. Future changes to drywell
 
air temperature and suppression chamber air tem perature instrumentation requirements will be subject to the controls of 10 CFR 50.59.
 
==5.0 REGULATORY ANALYSIS==
 
5.1 No Significant Hazards Consideration Exelon has evaluated whether or not a significant hazards consideration is involved with
 
the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
: 1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No. The failure of the drywell air temperature or suppression
 
chamber air temperature instrumentation is not assumed to be an initiator of any analyzed event in the UFSAR. The proposed changes do not alter the physical
 
design of this instrumentation or any ot her plant structure, system, or component.
The proposed changes relocate the drywell air temperature and suppression
 
chamber air temperature instrumentation operability and surveillance
 
requirements from the Limerick Generating Station (LGS) Technical License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation  Page 6 of 8
 
Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes
 
Specifications (TS) to a licensee-controlled document under the control of 10 CFR 50.59.
 
The proposed changes conform to NRC regulatory requirements regarding the
 
content of plant TS as identified in 10 CFR 50.36, and also the guidance as
 
approved by the NRC in NUREG-1433, "Standard Technical Specifications-
 
General Electric Plants, BWR/4."
 
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 relocate the drywell air temperature and
 
suppression chamber air temperature instrumentation operability and
 
surveillance requirements from the LG S TS to a licensee-controlled document under the control of 10 CFR 50.59.
The proposed changes do not alter the physical design, safety limits, or safety analysis assumptions associated with the
 
operation of the plant. Accordingly, the proposed changes do not introduce any
 
new accident initiators, nor do they reduce or adversely affect the capabilities of
 
any plant structure, system, or component in the performance of their safety function. 
 
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 subject instrumentation does not provide primary information
 
required to permit operators to take specific manually controlled actions for which
 
no automatic control is provided, and that are required for safety systems to accomplish their safety functions for design basis accident events. The
 
instrumentation provides only drywell air temperature indication and suppression
 
chamber air temperature indication, and does not provide an input to any
 
automatic safety function. Operab ility and surveillance requirements will be established in a licensee-controlled document to ensure the reliability of drywell


air temperature and suppression chamber air temperature instrumentation  
License Amendment Request                                                                Attachment 1 Changes to Accident Monitoring Instrumentation                                              Page 2 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes
: 4. Delete 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. This table identifies the surveillance requirements for this instrumentation, i.e., a channel check and channel calibration are specified. The frequency for performing these surveillance requirements is specified in the LGS SFCP, which will also be revised to delete the associated surveillance frequencies from the SFCP upon implementation of the approved amendment. The surveillance requirements from TS and the frequency for performing the surveillance requirements from the SFCP will be relocated to the LGS TRM.
Prior to implementation of the amendment, operability and surveillance requirements for the drywell air temperature and suppression chamber air temperature instrumentation will be incorporated into the LGS TRM. The operability requirements will identify compensatory measures and completion times for these instruments. Any subsequent changes to the TRM requirements will be performed in accordance with 10 CFR 50.59.
There are no changes to the TS Bases section proposed by this amendment application since the drywell air temperature and suppression chamber air temperature instrumentation is not specifically identified in the TS Bases.


capability. Changes to these requirements will be subject to the controls of 10
==3.0      BACKGROUND==


CFR 50.59, providing the appropriate level of regulatory control.  
The NRC provided guidance for the contents of TS in its Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors (58 FR 39132, July 22, 1993; Reference 4). In particular, the NRC indicated that certain items could be relocated from the TS to licensee-controlled documents. The Final Policy Statement identified future criteria to be used in determining whether particular safety functions are required to be included in the TS, as follows: (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; (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety. The NRC adopted amendments to 10 CFR 50.36 (60 FR 36953, July 19, 1995; Reference 5) to codify and incorporate these criteria.
The NRCs policy statement provides that those existing TS requirements which do not satisfy these four specified criteria may be relocated to licensee-controlled documents, such that future changes could be made to these provisions pursuant to 10 CFR 50.59. Subsequently, the nuclear steam supply system owners' groups and the NRC staff developed improved standard technical specifications (STS) that would establish models of the Commissions policy for each primary reactor type. The NRC issued the improved STS for General Electric BWR/4 plants as NUREG-1433, which was developed utilizing the guidance and criteria in the Commissions policy statement.


Therefore, the proposed changes do not involve a significant reduction in a
License Amendment Request                                                              Attachment 1 Changes to Accident Monitoring Instrumentation                                            Page 3 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes


margin of safety.  
==4.0    TECHNICAL ANALYSIS==


License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation  Page 7 of 8
The proposed license amendment relocates the drywell air temperature and suppression chamber air temperature instrumentation operability and surveillance requirements from the LGS TS to the LGS TRM. The TRM is referenced in the LGS UFSAR and is subject to the controls of 10 CFR 50.59. The TRM has been used to capture and control other requirements associated with previous LGS license amendments.
As discussed in the Background section above, an NRC policy statement concluded that those existing TS requirements which do not satisfy the screening criteria specified in 10 CFR 50.36 may be deleted from the TS, and the requirements established in licensee-controlled documents that are subject to the controls of 10 CFR 50.59. The NRC position on application of the screening criteria to accident monitoring instrumentation is documented in correspondence dated May 9, 1988, T. E. Murley (NRC) to R. F. Janecek (BWR Owners' Group) (Reference 6).
The NRC position is that Regulatory Guide 1.97 (Reference 7), Type A, and Category 1, accident monitoring instrumentation should be incorporated into the plants TS. The requirements for those instruments not meeting these criteria may be removed from the TS and established in a licensee-controlled document subject to the controls of 10 CFR 50.59.
Regulatory Guide 1.97, Revision 2, defines Type A instruments as those that monitor primary information required to permit the control room operator to take specific manually controlled actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for design basis accident events. Category 1 instruments are designed for full qualification, redundancy, continuous real-time display, and onsite (standby) power.
Regulatory Guide 1.97, Revision 2, designates drywell air temperature instrumentation as Type D, Category 2, instrumentation. Type D instruments provide information to indicate the operation of individual safety systems and other systems important to safety. Category 2 instruments are designed to less stringent qualifications that do not require seismic qualification, redundancy, or continuous display, and require only a high reliability power source (not necessarily standby power). From a plant-specific perspective, LGS UFSAR Section 7.5 and UFSAR Table 7.5-3 also identify the drywell air temperature instrumentation as Type D, Category 2. Relocating drywell air temperature instrumentation from the TS to a licensee-controlled document conforms with this NRC position on application of the screening criteria to accident monitoring instrumentation.
Regulatory Guide 1.97, Revision 2, does not include suppression chamber air temperature as an accident monitoring variable. Likewise, the LGS UFSAR does not specifically identify suppression chamber air temperature by itself as a Regulatory Guide 1.97 variable. However, LGS UFSAR Section 7.5 does describe the use of suppression chamber air temperature for monitoring the effectiveness of suppression chamber spray flow (a Type D, Category 2 variable).
Relocating suppression chamber air temperature instrumentation from the TS to a licensee-controlled document conforms with this NRC position on application of the screening criteria to accident monitoring instrumentation.


Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes  
License Amendment Request                                                              Attachment 1 Changes to Accident Monitoring Instrumentation                                            Page 4 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes NUREG-1433 identifies improved TS that were developed based on the screening criteria in the Final Commission Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors, that were subsequently codified in 10 CFR 50.36. According to NUREG-1433, accident monitoring instrumentation that satisfies the definition of Type A in Regulatory Guide 1.97 meets Criterion 3 of 10 CFR 50.36(c)(2)(ii). Also, Category I, non-Type A instrumentation is retained in TS because they are intended to assist operators in minimizing the consequences of accidents. Therefore, Category I, non-Type A variables are important for reducing public risk.
However, as stated previously, the LGS UFSAR indicates that the drywell air temperature instrumentation is Type D, Category 2 and suppression chamber air temperature is used for monitoring the effectiveness of suppression chamber spray flow (a Type D, Category 2 variable).
An assessment of the subject accident monitoring instrumentation against the four criterion of 10 CFR 50.36 is provided below.
Criterion 1: The drywell air temperature and suppression chamber air temperature instrumentation does not provide the primary information used to detect or indicate a significant abnormal degradation of the reactor coolant pressure boundary considered by Criterion 1. This is consistent with the Commissions Final Policy Statement which indicated that the first criterion was intended to assure that TS controlled those instruments specifically installed to detect reactor coolant leakage.
Criterion 2: The Commission's Final Policy Statement indicates that the basic concept in adequate protection of the public health and safety is that the plant be operated within the bounds of the initial conditions assumed in the existing design basis accident and transient analyses, and that the plant will be operated to preclude unanalyzed transients and accidents.
Therefore, Criterion 2 applies to process variables that are parameters for which specific values or ranges of values have been chosen as reference bounds in the design basis accident or transient analyses, and which are monitored and controlled during normal power operation such that process values remain within the analysis bounds. According to Regulatory Guide 1.97, Revision 2, accident monitoring instrumentation is provided to monitor plant variables and systems during and following design basis accidents or transients. Therefore, Criterion 2 does not apply to accident monitoring instrumentation since accident monitoring instrumentation provides indication of plant variables required by operators during accident conditions to take preplanned manual actions to accomplish safety functions rather than instrumentation that provides indication of process variables that are monitored and controlled by operators during normal plant operations to ensure that the initial conditions for accident analyses are met. As such, the drywell air temperature and suppression chamber air temperature instrumentation does not provide the primary information used to monitor process variables, design features or operating restrictions that are an initial condition of a design basis accident or transient analysis considered in Criterion 2.
Criterion 3: Drywell air temperature and suppression chamber air temperature instrumentation does not initiate any automatic safety function. Drywell air temperature and suppression chamber air temperature instrumentation is not used as the primary information required to permit operators to take specific manually controlled actions for which no automatic control is provided, and that are required for safety systems to accomplish their safety functions for design


Based on the above, Exelon concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.  
License Amendment Request                                                              Attachment 1 Changes to Accident Monitoring Instrumentation                                            Page 5 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes basis accident events. The drywell air temperature indication does indicate the performance of safety systems and other systems important to safety. As such, the drywell air temperature instrumentation is considered Type D, Category 2 (refer to Table 7.5-3 of the LGS UFSAR).
Suppression chamber air temperature is used for monitoring the effectiveness of suppression chamber spray flow (a Type D, Category 2 variable). Hence, drywell air temperature and suppression chamber air temperature instrumentation is not part of the primary success path used to mitigate a design basis accident or transient involving a failure of or challenge to the integrity of a fission product barrier considered in Criterion 3.
Criterion 4: The loss of the subject accident monitoring instrumentation has negligible effect on the probabilistic safety assessment, and has not been shown to be significant to public health and safety as considered in Criterion 4.
Consequently, the drywell air temperature and suppression chamber air temperature instrumentation does not meet any of the screening criteria contained in the Commission's Final Policy Statement and 10 CFR 50.36. This conclusion is supported by the NRC screening criteria for accident monitoring instrumentation required to be in TS as documented in Reference 6 and NUREG-1433 which indicate that only Regulatory Guide 1.97, Type A and Category 1, non-Type A instrumentation as defined by plant-specific analyses are required to be listed in the Accident Monitoring Instrumentation section of TS. As indicated previously, LGS UFSAR Section 7.5 designates the drywell air temperature and suppression chamber air temperature instrumentation as other than Type A or Category 1, non-Type A instrumentation. Accordingly, the drywell air temperature and suppression chamber air temperature instrumentation requirements can be established in a licensee-controlled document. Future changes to drywell air temperature and suppression chamber air temperature instrumentation requirements will be subject to the controls of 10 CFR 50.59.


5.2 Applicable Regulatory Requirements/Criteria The NRC provided guidance for the contents of TS in its "Final Policy Statement on
==5.0      REGULATORY ANALYSIS==


Technical Specifications Improvement for Nu clear Power Reactors" (58 FR 39132, July 22, 1993). In particular, the NRC indicated that certain items could be relocated from the  
5.1      No Significant Hazards Consideration Exelon has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:
: 1.      Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No. The failure of the drywell air temperature or suppression chamber air temperature instrumentation is not assumed to be an initiator of any analyzed event in the UFSAR. The proposed changes do not alter the physical design of this instrumentation or any other plant structure, system, or component.
The proposed changes relocate the drywell air temperature and suppression chamber air temperature instrumentation operability and surveillance requirements from the Limerick Generating Station (LGS) Technical


TS to licensee-controlled documents, and identified criteria to be used to determine the  
License Amendment Request                                                            Attachment 1 Changes to Accident Monitoring Instrumentation                                          Page 6 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes Specifications (TS) to a licensee-controlled document under the control of 10 CFR 50.59.
The proposed changes conform to NRC regulatory requirements regarding the content of plant TS as identified in 10 CFR 50.36, and also the guidance as approved by the NRC in NUREG-1433, Standard Technical Specifications-General Electric Plants, BWR/4.
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 relocate the drywell air temperature and suppression chamber air temperature instrumentation operability and surveillance requirements from the LGS TS to a licensee-controlled document under the control of 10 CFR 50.59. The proposed changes do not alter the physical design, safety limits, or safety analysis assumptions associated with the operation of the plant. Accordingly, the proposed changes do not introduce any new accident initiators, nor do they reduce or adversely affect the capabilities of any plant structure, system, or component in the performance of their safety function.
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 subject instrumentation does not provide primary information required to permit operators to take specific manually controlled actions for which no automatic control is provided, and that are required for safety systems to accomplish their safety functions for design basis accident events. The instrumentation provides only drywell air temperature indication and suppression chamber air temperature indication, and does not provide an input to any automatic safety function. Operability and surveillance requirements will be established in a licensee-controlled document to ensure the reliability of drywell air temperature and suppression chamber air temperature instrumentation capability. Changes to these requirements will be subject to the controls of 10 CFR 50.59, providing the appropriate level of regulatory control.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.


functions to be included in the TS. The NRC adopted revisions to 10 CFR 50.36 to  
License Amendment Request                                                              Attachment 1 Changes to Accident Monitoring Instrumentation                                            Page 7 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes Based on the above, Exelon concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.
5.2    Applicable Regulatory Requirements/Criteria The NRC provided guidance for the contents of TS in its Final Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors (58 FR 39132, July 22, 1993). In particular, the NRC indicated that certain items could be relocated from the TS to licensee-controlled documents, and identified criteria to be used to determine the functions to be included in the TS. The NRC adopted revisions to 10 CFR 50.36 to codify and incorporate these criteria. The NRC published in NUREG-1433 improved standard technical specifications indicating that Regulatory Guide 1.97, Type A and Category 1, non-Type A variables should be included in TS. The TS requirements proposed for relocation do not meet this criteria based on plant-specific analysis described in LGS UFSAR Section 7.5, and accordingly, are not required to be in the TS.
Operability and surveillance requirements for the drywell air temperature and suppression chamber air temperature instrumentation will be maintained in the LGS TRM, subject to the controls of 10 CFR 50.59.
In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.


codify and incorporate these criteria. The NRC published in NUREG-1433 improved
==6.0    ENVIRONMENTAL CONSIDERATION==


standard technical specifications indicating that Regulatory Guide 1.97, Type A and
A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.


Category 1, non-Type A variables should be included in TS. The TS requirements
==7.0    REFERENCES==
: 1. 10 CFR 50.36, Technical Specifications.
: 2. NUREG-1433, Standard Technical Specifications-General Electric Plants, BWR/4, Revision 3.1, dated December 1, 2005.


proposed for relocation do not meet this criteria based on plant-specific analysis
License Amendment Request                                                         Attachment 1 Changes to Accident Monitoring Instrumentation                                       Page 8 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes
 
: 3. Letter dated September 27, 2005, from T. Tate (USNRC) to C. Crane (Exelon Nuclear),
described in LGS UFSAR Section 7.5, and accordingly, are not required to be in the TS.
      "Limerick Generating Station, Units 1 and 2 - Issuance of Amendments RE: Relocation of Operability and Surveillance Requirements for the Safety/Relief Valve Position Instrumentation (TAC Nos. MC3454 and MC3455)."
 
: 4. NRC Final Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors, 58 FR 39132, dated July 22, 1993.
Operability and surveillance requirements for the drywell air temperature and
: 5. NRC Final Rule, 10 CFR 50.36, Technical Specifications, 60 FR 36953 (July 19, 1995).
 
suppression chamber air temperature instrumentation will be maintained in the LGS
 
TRM, subject to the controls of 10 CFR 50.59.
 
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 amendment will not be inimical to
 
the common defense and security or to the health and safety of the public.
 
==6.0 ENVIRONMENTAL CONSIDERATION==
 
A review has determined that the proposed amendment would change a requirement
 
with respect to installation or use of a facility component located within the restricted
 
area, as defined in 10 CFR 20, or would change an inspection or surveillance
 
requirement. However, the proposed amendment does not involve (i) a significant
 
hazards consideration, (ii) a significant change in the types or significant increase in the
 
amounts of any effluent that may be released offsite, or (iii) a significant increase in
 
individual or cumulative occupational radiation exposure. Accordingly, the proposed
 
amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR
 
51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact
 
statement or environmental assessment need be prepared in connection with the
 
proposed amendment.
 
==7.0 REFERENCES==
: 1. 10 CFR 50.36, "Technical Specifications."
: 2. NUREG-1433, "Standard Technical Specifications-General Electric Plants, BWR/4,"
Revision 3.1, dated December 1, 2005.
License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation Page 8 of 8  
 
Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes
: 3. Letter dated September 27, 2005, from T. Tate (USNRC) to C. Crane (Exelon Nuclear), "Limerick Generating Station, Units 1 and 2 - Issuance of Amendments RE: Relocation  
 
of Operability and Surveillance Requirement s for the Safety/Relief Valve Position Instrumentation (TAC Nos. MC3454 and MC3455)." 4. NRC "Final Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors," 58 FR 39132, dated July 22, 1993.
: 5. NRC Final Rule, 10 CFR 50.36, "Technical Specifications," 60 FR 36953 (July 19, 1995).
: 6. Letter, T. E. Murley (USNRC) to R. F. Janecek (BWR Owners' Group), dated May 9, 1988.
: 6. Letter, T. E. Murley (USNRC) to R. F. Janecek (BWR Owners' Group), dated May 9, 1988.
: 7. Regulatory Guide 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," Revision 2, dated December 1980.  
: 7. Regulatory Guide 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision 2, dated December 1980.


ATTACHMENT 2 License Amendment Request Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353  
ATTACHMENT 2 License Amendment Request Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 Proposed Changes to Accident Monitoring Instrumentation Technical Specifications Markup of Proposed Technical Specifications Pages Unit 1 TS Pages 3/4 3-85 3/4 3-87 Unit 2 TS Pages 3/4 3-85 3/4 3-87


Proposed Changes to Accident Monitoring Instrumentation Tec hnical Specifications Markup of Proposed Technical Specifications Pages Unit 1 TS Pages 3/4 3-85 3/4 3-87  Unit 2 TS Pages 3/4 3-85 3/4 3-87 TABLE 3.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION
TABLE 3.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION MINIMUM     APPLICABLE REQUIRED NUMBER       CHANNELS     OPERATIONAL INSTRUMENT                                                 OF CHANNELS         OPERABLE     CONDITIONS   ACTION
 
: 1. Reactor Vessel Pressure                                   2                   1         1,2         80
MINIMUM APPLICABLE REQUIRED NUMBER CHANNELS OPERATIONAL  
: 2. Reactor Vessel Water Level                               2                   1         1,2         80
 
: 3. Suppression Chamber Water Level                           2                   1         1,2         80
INSTRUMENT   OF CHANNELS   OPERABLE CONDITIONS ACTION
: 4. Suppression Chamber Water Temperature                     8, 6 locations       6,       1,2         80 1/location
: 1. Reactor Vessel Pressure 2 1 1,2 80
: 5. Suppression Chamber Air Temperature Deleted               1                   1         1,2         80
: 2. Reactor Vessel Water Level 2 1 1,2 80
: 6. Drywell Pressure                                         2                   1         1,2         80
: 3. Suppression Chamber Water Level 2 1 1,2 80
: 7. Drywell Air Temperature Deleted                           1                   1         1,2         80
: 4. Suppression Chamber Water Temperature 8, 6 locations 6, 1,2 80  
 
1/location
: 5. Suppression Chamber Air Temperature Deleted 1 1 1,2 80
: 6. Drywell Pressure 2 1 1,2 80
: 7. Drywell Air Temperature Deleted 1 1 1,2 80
: 8. Deleted
: 8. Deleted
: 9. Deleted
: 9. Deleted
: 10. Deleted
: 10. Deleted
: 11. Primary Containment Post-LOCA Radiation Monitors 4 2 1,2,3 81
: 11. Primary Containment Post-LOCA Radiation Monitors         4                   2         1,2,3       81
: 12. North Stack Wide Range Accident Monitor** 3* 3* 1,2,3 81  
: 12. North Stack Wide Range Accident Monitor**                 3*                   3*       1,2,3       81 13   Neutron Flux                                             2                   1         1,2         80 LIMERICK - UNIT 1                                     3/4 3-85                 Amendment No. 29, 151, 173, 179
 
13 Neutron Flux 2 1 1,2 80  
 
LIMERICK - UNIT 1 3/4 3-85 Amendment No. 29 , 151 , 173 , 179 TABLE 4.3.7.5-1
 
ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS
 
CHANNEL  CHANNEL 


INSTRUMENT   CHECK(a) CALIBRATION(a)
TABLE 4.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL            CHANNEL INSTRUMENT                                                           CHECK(a)         CALIBRATION(a)
: 1. Reactor Vessel Pressure
: 1. Reactor Vessel Pressure
: 2. Reactor Vessel Water Level
: 2. Reactor Vessel Water Level
Line 537: Line 171:
: 9. Deleted
: 9. Deleted
: 10. Deleted
: 10. Deleted
: 11. Primary Containment Post LOCA Radiation Monitors   **
: 11. Primary Containment Post LOCA Radiation Monitors                                       **
: 12. North Stack Wide Range Accident Monitor***
: 12. North Stack Wide Range Accident Monitor***
: 13. Neutron Flux    
: 13. Neutron Flux (a) Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.
 
  **CHANNEL CALIBRATION shall consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/h and a one point calibration check of the detector below 10 R/h with an installed or portable gamma source.
(a) Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.  
***High range noble gas monitors.
 
LIMERICK - UNIT 1                                    3/4 3-87                    Amendment No. 116, 173, 179, 186
  **CHANNEL CALIBRATION shall consist of an electronic calibration of the channel, not including the detector,


for range decades above 10 R/h and a one point calibration check of the detector below 10 R/h with an
TABLE 3.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION MINIMUM     APPLICABLE REQUIRED NUMBER       CHANNELS     OPERATIONAL INSTRUMENT                                                     OF CHANNELS         OPERABLE     CONDITIONS   ACTION
 
: 1. Reactor Vessel Pressure                                       2                   1         1,2           80
installed or portable gamma source.
: 2. Reactor Vessel Water Level                                     2                   1         1,2           80
 
: 3. Suppression Chamber Water Level                               2                   1         1,2           80
***High range noble gas monitors.
: 4. Suppression Chamber Water Temperature                         8, 6 locations     6,         1,2           80 1/location
 
: 5. Suppression Chamber Air Temperature Deleted                   1                   1         1,2           80
LIMERICK - UNIT 1 3/4 3-87 Amendment No. 116 , 173 , 179 , 186 TABLE 3.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION
: 6. Drywell Pressure                                               2                   1         1,2           80
 
: 7. Drywell Air Temperature Deleted                               1                   1         1,2           80
MINIMUM APPLICABLE REQUIRED NUMBER CHANNELS OPERATIONAL INSTRUMENT   OF CHANNELS   OPERABLE CONDITIONS ACTION
: 1. Reactor Vessel Pressure 2 1 1,2 80
: 2. Reactor Vessel Water Level 2 1 1,2 80
: 3. Suppression Chamber Water Level 2 1 1,2 80
: 4. Suppression Chamber Water Temperature 8, 6 locations 6, 1,2 80  
 
1/location
: 5. Suppression Chamber Air Temperature Deleted 1 1 1,2 80
: 6. Drywell Pressure 2 1 1,2 80
: 7. Drywell Air Temperature Deleted 1 1 1,2 80
: 8. Deleted
: 8. Deleted
: 9. Deleted
: 9. Deleted
: 10. Deleted
: 10. Deleted
: 11. Primary Containment Post-LOCA Radiation Monitors 4 2 1,2,3 81
: 11. Primary Containment Post-LOCA Radiation Monitors               4                   2         1,2,3         81
: 12. North Stack Wide Range Accident Monitor** 3* 3* 1,2,3 81
: 12. North Stack Wide Range Accident Monitor**                       3*                 3*         1,2,3         81
: 13. Neutron Flux 2 1 1,2 80  
: 13. Neutron Flux                                                   2                   1         1,2           80 LIMERICK - UNIT 2                                        3/4 3-85                          Amendment No. 115, 135, 141


LIMERICK - UNIT 2 3/4 3-85 Amendment No. 115 , 135 , 141 TABLE 4.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS
TABLE 4.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL                   CHANNEL INSTRUMENT                                                             CHECK (a)             CALIBRATION (a)
 
CHANNEL   CHANNEL INSTRUMENT CHECK (a) CALIBRATION (a)
: 1. Reactor Vessel Pressure
: 1. Reactor Vessel Pressure
: 2. Reactor Vessel Water Level
: 2. Reactor Vessel Water Level
Line 583: Line 204:
: 9. Deleted
: 9. Deleted
: 10. Deleted
: 10. Deleted
: 11. Primary Containment Post LOCA Radiation Monitors **
: 11. Primary Containment Post LOCA Radiation Monitors                                             **
: 12. North Stack Wide Range Accident Monitor***
: 12. North Stack Wide Range Accident Monitor***
: 13. Neutron Flux  
: 13. Neutron Flux (a) Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.
 
  **CHANNEL CALIBRATION shall consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/h and a one point calibration check of the detector below 10 R/h with an installed or portable gamma source.
(a) Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.  
***High range noble gas monitors.
 
LIMERICK - UNIT 2                                       3/4 3-87                         Amendment No. 78, 135, 141, 147}}
  **CHANNEL CALIBRATION shall consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/h and a one point calibration check of the detector below 10 R/h with an  
 
installed or portable gamma source.  
***High range noble gas monitors.  
 
LIMERICK - UNIT 2 3/4 3-87 Amendment No. 78 , 135 , 141 , 147}}

Latest revision as of 06:01, 23 November 2019

License Amendment Request, Proposed Changes to Accident Monitoring Instrumentation Technical Specifications
ML071780293
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 06/27/2007
From: Cowan P
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML071780293 (16)


Text

Exelon Nuclear www.exe1oncorp.com 200 Exelon Way Nuclear Kennett Square, PA 19348 10 CFR 50.90 June 27,2007 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket N o . c i a n c L 5 0 - 3 5 3

SUBJECT:

License Amendment Request Proposed Changes to Accident Monitoring Instrumentation Technical Specifications Pursuant to 10 CFR 50.90, "Application for amendment of license or construction permit,"

Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively.

The proposed changes relocate the operability and surveillance requirements for the drywell air temperature and suppression chamber air temperature instrumentation from LGS TS Section 3.3.7.5, "Accident Monitoring Instrumentation," to the LGS Technical Requirements Manual (TRM).

The proposed changes conform to 10 CFR 50.36 for the contents of TS, and to the improved Standard Technical Specifications approved by the NRC in NUREG-1433, "Standard Technical Specifications - General Electric Plants, BWRI4." A similar change, to relocate the operability and surveillance requirements for the safetyhelief valve position indication instrumentation from TS Section 3.3.7.5 to the TRM, was approved by the NRC by issuance of Amendment Nos. 179 and 141 for LGS, Units 1 and 2, respectively, by letter dated September 27, 2005.

Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10CFR 50.92.

This amendment request contains no regulatory commitments.

Exelon requests approval of the proposed amendment by June 27,2008. Upon NRC approval, the amendment shall be implemented within 60 days of issuance.

These proposed changes have been reviewed by the Plant Operations Review Committee.

License Amendment Request Changes to Accident Monitoring Instrumentation Docket Nos. 50-352 and 50-353 June 27,2007 Page 2 We are notifying the State of Pennsylvania of this application for changes to the Technical Specifications by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Glenn Stewart at 610-765-5529.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 27th day of June, 2007.

Respectfully, Pamela B. &wan Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes

2. Markup of Proposed Technical Specifications Pages cc: Regional Administrator - NRC Region I W/ attachments NRC Senior Resident Inspector - Limerick Generating Station I1 NRC Project Manager, NRR - Limerick Generating Station 11 Director, Bureau of Radiation Protection - Pennsylvania Department I1 of Environmental Protection

ATTACHMENT 1 License Amendment Request Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 EVALUATION OF PROPOSED CHANGES

Subject:

Proposed Changes to Accident Monitoring Instrumentation Technical Specifications

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

S

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation Page 1 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes

1.0 DESCRIPTION

Pursuant to 10 CFR 50.90, Application for amendment of license or construction permit, Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS),

Appendix A of Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively.

The proposed changes relocate the operability and surveillance requirements for the drywell air temperature and suppression chamber air temperature instrumentation from the Accident Monitoring Instrumentation section of TS, i.e., from LGS TS 3.3.7.5 and 4.3.7.5 to the LGS Technical Requirements Manual (TRM). The TRM is incorporated by reference into the LGS Updated Final Safety Analysis Report (UFSAR) and is subject to the controls of 10 CFR 50.59.

Accordingly, any future changes to the drywell air temperature and suppression chamber air temperature instrumentation operability and surveillance requirements will be performed pursuant to 10 CFR 50.59.

The proposed changes conform to 10 CFR 50.36 (Reference 1) for the contents of TS, and to the improved Standard Technical Specifications approved by the NRC in NUREG-1433, Standard Technical Specifications - General Electric Plants, BWR/4 (Reference 2). A similar change, to relocate the operability and surveillance requirements for the safety/relief valve position indication instrumentation from TS Section 3.3.7.5 to the TRM, was approved by the NRC by issuance of Amendment Nos. 179 and 141 for LGS, Units 1 and 2, respectively (Reference 3).

2.0 PROPOSED CHANGE

S The changes requested by this amendment application are described below.

1. Delete Item 5, Suppression Chamber Air Temperature, from TS Table 3.3.7.5-1, "Accident Monitoring Instrumentation, on TS page 3/4 3-85. This table identifies the operability requirements for this instrumentation.
2. Delete Item 7, Drywell Air Temperature, from TS Table 3.3.7.5-1, "Accident Monitoring Instrumentation, on TS page 3/4 3-85. This table identifies the operability requirements for this instrumentation.
3. Delete 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. This table identifies the surveillance requirements for this instrumentation, i.e., a channel check and channel calibration are specified. The frequency for performing these surveillance requirements is specified in the LGS Surveillance Frequency Control Program (SFCP), which will also be revised to delete the associated surveillance frequencies from the SFCP upon implementation of the approved amendment. The surveillance requirements from TS and the frequency for performing the surveillance requirements from the SFCP will be relocated to the LGS TRM.

License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation Page 2 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes

4. Delete 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. This table identifies the surveillance requirements for this instrumentation, i.e., a channel check and channel calibration are specified. The frequency for performing these surveillance requirements is specified in the LGS SFCP, which will also be revised to delete the associated surveillance frequencies from the SFCP upon implementation of the approved amendment. The surveillance requirements from TS and the frequency for performing the surveillance requirements from the SFCP will be relocated to the LGS TRM.

Prior to implementation of the amendment, operability and surveillance requirements for the drywell air temperature and suppression chamber air temperature instrumentation will be incorporated into the LGS TRM. The operability requirements will identify compensatory measures and completion times for these instruments. Any subsequent changes to the TRM requirements will be performed in accordance with 10 CFR 50.59.

There are no changes to the TS Bases section proposed by this amendment application since the drywell air temperature and suppression chamber air temperature instrumentation is not specifically identified in the TS Bases.

3.0 BACKGROUND

The NRC provided guidance for the contents of TS in its Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors (58 FR 39132, July 22, 1993; Reference 4). In particular, the NRC indicated that certain items could be relocated from the TS to licensee-controlled documents. The Final Policy Statement identified future criteria to be used in determining whether particular safety functions are required to be included in the TS, as follows: (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; (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety. The NRC adopted amendments to 10 CFR 50.36 (60 FR 36953, July 19, 1995; Reference 5) to codify and incorporate these criteria.

The NRCs policy statement provides that those existing TS requirements which do not satisfy these four specified criteria may be relocated to licensee-controlled documents, such that future changes could be made to these provisions pursuant to 10 CFR 50.59. Subsequently, the nuclear steam supply system owners' groups and the NRC staff developed improved standard technical specifications (STS) that would establish models of the Commissions policy for each primary reactor type. The NRC issued the improved STS for General Electric BWR/4 plants as NUREG-1433, which was developed utilizing the guidance and criteria in the Commissions policy statement.

License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation Page 3 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes

4.0 TECHNICAL ANALYSIS

The proposed license amendment relocates the drywell air temperature and suppression chamber air temperature instrumentation operability and surveillance requirements from the LGS TS to the LGS TRM. The TRM is referenced in the LGS UFSAR and is subject to the controls of 10 CFR 50.59. The TRM has been used to capture and control other requirements associated with previous LGS license amendments.

As discussed in the Background section above, an NRC policy statement concluded that those existing TS requirements which do not satisfy the screening criteria specified in 10 CFR 50.36 may be deleted from the TS, and the requirements established in licensee-controlled documents that are subject to the controls of 10 CFR 50.59. The NRC position on application of the screening criteria to accident monitoring instrumentation is documented in correspondence dated May 9, 1988, T. E. Murley (NRC) to R. F. Janecek (BWR Owners' Group) (Reference 6).

The NRC position is that Regulatory Guide 1.97 (Reference 7), Type A, and Category 1, accident monitoring instrumentation should be incorporated into the plants TS. The requirements for those instruments not meeting these criteria may be removed from the TS and established in a licensee-controlled document subject to the controls of 10 CFR 50.59.

Regulatory Guide 1.97, Revision 2, defines Type A instruments as those that monitor primary information required to permit the control room operator to take specific manually controlled actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for design basis accident events. Category 1 instruments are designed for full qualification, redundancy, continuous real-time display, and onsite (standby) power.

Regulatory Guide 1.97, Revision 2, designates drywell air temperature instrumentation as Type D, Category 2, instrumentation. Type D instruments provide information to indicate the operation of individual safety systems and other systems important to safety. Category 2 instruments are designed to less stringent qualifications that do not require seismic qualification, redundancy, or continuous display, and require only a high reliability power source (not necessarily standby power). From a plant-specific perspective, LGS UFSAR Section 7.5 and UFSAR Table 7.5-3 also identify the drywell air temperature instrumentation as Type D, Category 2. Relocating drywell air temperature instrumentation from the TS to a licensee-controlled document conforms with this NRC position on application of the screening criteria to accident monitoring instrumentation.

Regulatory Guide 1.97, Revision 2, does not include suppression chamber air temperature as an accident monitoring variable. Likewise, the LGS UFSAR does not specifically identify suppression chamber air temperature by itself as a Regulatory Guide 1.97 variable. However, LGS UFSAR Section 7.5 does describe the use of suppression chamber air temperature for monitoring the effectiveness of suppression chamber spray flow (a Type D, Category 2 variable).

Relocating suppression chamber air temperature instrumentation from the TS to a licensee-controlled document conforms with this NRC position on application of the screening criteria to accident monitoring instrumentation.

License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation Page 4 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes NUREG-1433 identifies improved TS that were developed based on the screening criteria in the Final Commission Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors, that were subsequently codified in 10 CFR 50.36. According to NUREG-1433, accident monitoring instrumentation that satisfies the definition of Type A in Regulatory Guide 1.97 meets Criterion 3 of 10 CFR 50.36(c)(2)(ii). Also, Category I, non-Type A instrumentation is retained in TS because they are intended to assist operators in minimizing the consequences of accidents. Therefore, Category I, non-Type A variables are important for reducing public risk.

However, as stated previously, the LGS UFSAR indicates that the drywell air temperature instrumentation is Type D, Category 2 and suppression chamber air temperature is used for monitoring the effectiveness of suppression chamber spray flow (a Type D, Category 2 variable).

An assessment of the subject accident monitoring instrumentation against the four criterion of 10 CFR 50.36 is provided below.

Criterion 1: The drywell air temperature and suppression chamber air temperature instrumentation does not provide the primary information used to detect or indicate a significant abnormal degradation of the reactor coolant pressure boundary considered by Criterion 1. This is consistent with the Commissions Final Policy Statement which indicated that the first criterion was intended to assure that TS controlled those instruments specifically installed to detect reactor coolant leakage.

Criterion 2: The Commission's Final Policy Statement indicates that the basic concept in adequate protection of the public health and safety is that the plant be operated within the bounds of the initial conditions assumed in the existing design basis accident and transient analyses, and that the plant will be operated to preclude unanalyzed transients and accidents.

Therefore, Criterion 2 applies to process variables that are parameters for which specific values or ranges of values have been chosen as reference bounds in the design basis accident or transient analyses, and which are monitored and controlled during normal power operation such that process values remain within the analysis bounds. According to Regulatory Guide 1.97, Revision 2, accident monitoring instrumentation is provided to monitor plant variables and systems during and following design basis accidents or transients. Therefore, Criterion 2 does not apply to accident monitoring instrumentation since accident monitoring instrumentation provides indication of plant variables required by operators during accident conditions to take preplanned manual actions to accomplish safety functions rather than instrumentation that provides indication of process variables that are monitored and controlled by operators during normal plant operations to ensure that the initial conditions for accident analyses are met. As such, the drywell air temperature and suppression chamber air temperature instrumentation does not provide the primary information used to monitor process variables, design features or operating restrictions that are an initial condition of a design basis accident or transient analysis considered in Criterion 2.

Criterion 3: Drywell air temperature and suppression chamber air temperature instrumentation does not initiate any automatic safety function. Drywell air temperature and suppression chamber air temperature instrumentation is not used as the primary information required to permit operators to take specific manually controlled actions for which no automatic control is provided, and that are required for safety systems to accomplish their safety functions for design

License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation Page 5 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes basis accident events. The drywell air temperature indication does indicate the performance of safety systems and other systems important to safety. As such, the drywell air temperature instrumentation is considered Type D, Category 2 (refer to Table 7.5-3 of the LGS UFSAR).

Suppression chamber air temperature is used for monitoring the effectiveness of suppression chamber spray flow (a Type D, Category 2 variable). Hence, drywell air temperature and suppression chamber air temperature instrumentation is not part of the primary success path used to mitigate a design basis accident or transient involving a failure of or challenge to the integrity of a fission product barrier considered in Criterion 3.

Criterion 4: The loss of the subject accident monitoring instrumentation has negligible effect on the probabilistic safety assessment, and has not been shown to be significant to public health and safety as considered in Criterion 4.

Consequently, the drywell air temperature and suppression chamber air temperature instrumentation does not meet any of the screening criteria contained in the Commission's Final Policy Statement and 10 CFR 50.36. This conclusion is supported by the NRC screening criteria for accident monitoring instrumentation required to be in TS as documented in Reference 6 and NUREG-1433 which indicate that only Regulatory Guide 1.97, Type A and Category 1, non-Type A instrumentation as defined by plant-specific analyses are required to be listed in the Accident Monitoring Instrumentation section of TS. As indicated previously, LGS UFSAR Section 7.5 designates the drywell air temperature and suppression chamber air temperature instrumentation as other than Type A or Category 1, non-Type A instrumentation. Accordingly, the drywell air temperature and suppression chamber air temperature instrumentation requirements can be established in a licensee-controlled document. Future changes to drywell air temperature and suppression chamber air temperature instrumentation requirements will be subject to the controls of 10 CFR 50.59.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Exelon has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

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

Response: No. The failure of the drywell air temperature or suppression chamber air temperature instrumentation is not assumed to be an initiator of any analyzed event in the UFSAR. The proposed changes do not alter the physical design of this instrumentation or any other plant structure, system, or component.

The proposed changes relocate the drywell air temperature and suppression chamber air temperature instrumentation operability and surveillance requirements from the Limerick Generating Station (LGS) Technical

License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation Page 6 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes Specifications (TS) to a licensee-controlled document under the control of 10 CFR 50.59.

The proposed changes conform to NRC regulatory requirements regarding the content of plant TS as identified in 10 CFR 50.36, and also the guidance as approved by the NRC in NUREG-1433, Standard Technical Specifications-General Electric Plants, BWR/4.

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 relocate the drywell air temperature and suppression chamber air temperature instrumentation operability and surveillance requirements from the LGS TS to a licensee-controlled document under the control of 10 CFR 50.59. The proposed changes do not alter the physical design, safety limits, or safety analysis assumptions associated with the operation of the plant. Accordingly, the proposed changes do not introduce any new accident initiators, nor do they reduce or adversely affect the capabilities of any plant structure, system, or component in the performance of their safety function.

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 subject instrumentation does not provide primary information required to permit operators to take specific manually controlled actions for which no automatic control is provided, and that are required for safety systems to accomplish their safety functions for design basis accident events. The instrumentation provides only drywell air temperature indication and suppression chamber air temperature indication, and does not provide an input to any automatic safety function. Operability and surveillance requirements will be established in a licensee-controlled document to ensure the reliability of drywell air temperature and suppression chamber air temperature instrumentation capability. Changes to these requirements will be subject to the controls of 10 CFR 50.59, providing the appropriate level of regulatory control.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation Page 7 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes Based on the above, Exelon concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

5.2 Applicable Regulatory Requirements/Criteria The NRC provided guidance for the contents of TS in its Final Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors (58 FR 39132, July 22, 1993). In particular, the NRC indicated that certain items could be relocated from the TS to licensee-controlled documents, and identified criteria to be used to determine the functions to be included in the TS. The NRC adopted revisions to 10 CFR 50.36 to codify and incorporate these criteria. The NRC published in NUREG-1433 improved standard technical specifications indicating that Regulatory Guide 1.97, Type A and Category 1, non-Type A variables should be included in TS. The TS requirements proposed for relocation do not meet this criteria based on plant-specific analysis described in LGS UFSAR Section 7.5, and accordingly, are not required to be in the TS.

Operability and surveillance requirements for the drywell air temperature and suppression chamber air temperature instrumentation will be maintained in the LGS TRM, subject to the controls of 10 CFR 50.59.

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

6.0 ENVIRONMENTAL CONSIDERATION

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

7.0 REFERENCES

1. 10 CFR 50.36, Technical Specifications.
2. NUREG-1433, Standard Technical Specifications-General Electric Plants, BWR/4, Revision 3.1, dated December 1, 2005.

License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation Page 8 of 8 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes

3. Letter dated September 27, 2005, from T. Tate (USNRC) to C. Crane (Exelon Nuclear),

"Limerick Generating Station, Units 1 and 2 - Issuance of Amendments RE: Relocation of Operability and Surveillance Requirements for the Safety/Relief Valve Position Instrumentation (TAC Nos. MC3454 and MC3455)."

4. NRC Final Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors, 58 FR 39132, dated July 22, 1993.
5. NRC Final Rule, 10 CFR 50.36, Technical Specifications, 60 FR 36953 (July 19, 1995).
6. Letter, T. E. Murley (USNRC) to R. F. Janecek (BWR Owners' Group), dated May 9, 1988.
7. Regulatory Guide 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision 2, dated December 1980.

ATTACHMENT 2 License Amendment Request Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 Proposed Changes to Accident Monitoring Instrumentation Technical Specifications Markup of Proposed Technical Specifications Pages Unit 1 TS Pages 3/4 3-85 3/4 3-87 Unit 2 TS Pages 3/4 3-85 3/4 3-87

TABLE 3.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION MINIMUM APPLICABLE REQUIRED NUMBER CHANNELS OPERATIONAL INSTRUMENT OF CHANNELS OPERABLE CONDITIONS ACTION

1. Reactor Vessel Pressure 2 1 1,2 80
2. Reactor Vessel Water Level 2 1 1,2 80
3. Suppression Chamber Water Level 2 1 1,2 80
4. Suppression Chamber Water Temperature 8, 6 locations 6, 1,2 80 1/location
5. Suppression Chamber Air Temperature Deleted 1 1 1,2 80
6. Drywell Pressure 2 1 1,2 80
7. Drywell Air Temperature Deleted 1 1 1,2 80
8. Deleted
9. Deleted
10. Deleted
11. Primary Containment Post-LOCA Radiation Monitors 4 2 1,2,3 81
12. North Stack Wide Range Accident Monitor** 3* 3* 1,2,3 81 13 Neutron Flux 2 1 1,2 80 LIMERICK - UNIT 1 3/4 3-85 Amendment No. 29, 151, 173, 179

TABLE 4.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL CHANNEL INSTRUMENT CHECK(a) CALIBRATION(a)

1. Reactor Vessel Pressure
2. Reactor Vessel Water Level
3. Suppression Chamber Water Level
4. Suppression Chamber Water Temperature
5. Suppression Chamber Air Temperature Deleted
6. Primary Containment Pressure
7. Drywell Air Temperature Deleted
8. Deleted
9. Deleted
10. Deleted
11. Primary Containment Post LOCA Radiation Monitors **
12. North Stack Wide Range Accident Monitor***
13. Neutron Flux (a) Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.
    • CHANNEL CALIBRATION shall consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/h and a one point calibration check of the detector below 10 R/h with an installed or portable gamma source.
      • High range noble gas monitors.

LIMERICK - UNIT 1 3/4 3-87 Amendment No. 116, 173, 179, 186

TABLE 3.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION MINIMUM APPLICABLE REQUIRED NUMBER CHANNELS OPERATIONAL INSTRUMENT OF CHANNELS OPERABLE CONDITIONS ACTION

1. Reactor Vessel Pressure 2 1 1,2 80
2. Reactor Vessel Water Level 2 1 1,2 80
3. Suppression Chamber Water Level 2 1 1,2 80
4. Suppression Chamber Water Temperature 8, 6 locations 6, 1,2 80 1/location
5. Suppression Chamber Air Temperature Deleted 1 1 1,2 80
6. Drywell Pressure 2 1 1,2 80
7. Drywell Air Temperature Deleted 1 1 1,2 80
8. Deleted
9. Deleted
10. Deleted
11. Primary Containment Post-LOCA Radiation Monitors 4 2 1,2,3 81
12. North Stack Wide Range Accident Monitor** 3* 3* 1,2,3 81
13. Neutron Flux 2 1 1,2 80 LIMERICK - UNIT 2 3/4 3-85 Amendment No. 115, 135, 141

TABLE 4.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL CHANNEL INSTRUMENT CHECK (a) CALIBRATION (a)

1. Reactor Vessel Pressure
2. Reactor Vessel Water Level
3. Suppression Chamber Water Level
4. Suppression Chamber Water Temperature
5. Suppression Chamber Air Temperature Deleted
6. Primary Containment Pressure
7. Drywell Air Temperature Deleted
8. Deleted
9. Deleted
10. Deleted
11. Primary Containment Post LOCA Radiation Monitors **
12. North Stack Wide Range Accident Monitor***
13. Neutron Flux (a) Frequencies are specified in the Surveillance Frequency Control Program unless otherwise noted in the table.
    • CHANNEL CALIBRATION shall consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/h and a one point calibration check of the detector below 10 R/h with an installed or portable gamma source.
      • High range noble gas monitors.

LIMERICK - UNIT 2 3/4 3-87 Amendment No. 78, 135, 141, 147