ML071780293: Difference between revisions
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| issue date = 06/27/2007 | | issue date = 06/27/2007 | ||
| title = License Amendment Request, Proposed Changes to Accident Monitoring Instrumentation Technical Specifications | | title = License Amendment Request, Proposed Changes to Accident Monitoring Instrumentation Technical Specifications | ||
| author name = Cowan P | | author name = Cowan P | ||
| author affiliation = Exelon Generation Co, LLC, Exelon Nuclear | | author affiliation = Exelon Generation Co, LLC, Exelon Nuclear | ||
| addressee name = | | addressee name = | ||
Line 29: | Line 29: | ||
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: | & Regulatory Affairs Exelon Generation Company, LLC Attachments: | ||
: 1. Evaluation of Proposed Changes | : 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 | : 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 | ||
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==2.0 PROPOSED CHANGE== | ==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. | 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 | : 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. | 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 | : 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 | ||
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License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation Page 2 of 8 | 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 | 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 | : 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 | ||
Line 351: | Line 351: | ||
5.1 No Significant Hazards Consideration Exelon has evaluated whether or not a significant hazards consideration is involved with | 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: | 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? | : 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 | Response: No. The failure of the drywell air temperature or suppression | ||
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Therefore, the proposed changes do not involve a significant increase in the | Therefore, the proposed changes do not involve a significant increase in the | ||
probability or consequences of an accident previously evaluated. | 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? | : 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 | Response: No. The proposed changes relocate the drywell air temperature and | ||
Line 395: | Line 395: | ||
Therefore, the proposed changes do not create the possibility of a new or | Therefore, the proposed changes do not create the possibility of a new or | ||
different kind of accident from any accident previously evaluated. | 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 | : 3. Do the proposed changes involve a significant reduction in a margin of safety? Response: No. The subject instrumentation does not provide primary information | ||
Line 424: | Line 424: | ||
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. | 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 | |||
Regulatory Requirements/Criteria The NRC provided guidance for the contents of TS in its "Final Policy Statement on | |||
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 | 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 | ||
Line 484: | Line 483: | ||
==7.0 REFERENCES== | ==7.0 REFERENCES== | ||
: 1. 10 CFR 50.36, "Technical Specifications." | : 1. 10 CFR 50.36, "Technical Specifications." | ||
: 2. NUREG-1433, "Standard Technical Specifications-General Electric Plants, BWR/4," | : 2. NUREG-1433, "Standard Technical Specifications-General Electric Plants, BWR/4," | ||
Revision 3.1, dated December 1, 2005. | Revision 3.1, dated December 1, 2005. | ||
License Amendment Request Attachment 1 Changes to Accident Monitoring Instrumentation Page 8 of 8 | 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 | 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 | : 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. | 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). | : 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. | ||
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MINIMUM APPLICABLE REQUIRED NUMBER CHANNELS OPERATIONAL | MINIMUM APPLICABLE REQUIRED NUMBER CHANNELS OPERATIONAL | ||
INSTRUMENT OF CHANNELS OPERABLE CONDITIONS ACTION | INSTRUMENT OF CHANNELS OPERABLE CONDITIONS ACTION | ||
: 1. Reactor Vessel Pressure 2 1 1,2 80 | : 1. Reactor Vessel Pressure 2 1 1,2 80 | ||
: 2. Reactor Vessel Water Level 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 | : 3. Suppression Chamber Water Level 2 1 1,2 80 | ||
: 4. Suppression Chamber Water Temperature 8, 6 locations 6, 1,2 80 | : 4. Suppression Chamber Water Temperature 8, 6 locations 6, 1,2 80 | ||
1/location | 1/location | ||
: 5. Suppression Chamber Air Temperature Deleted 1 1 1,2 80 | : 5. Suppression Chamber Air Temperature Deleted 1 1 1,2 80 | ||
: 6. Drywell Pressure 2 1 1,2 80 | : 6. Drywell Pressure 2 1 1,2 80 | ||
: 7. Drywell Air Temperature Deleted 1 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 | ||
Line 528: | Line 527: | ||
INSTRUMENT CHECK(a) CALIBRATION(a) | INSTRUMENT CHECK(a) CALIBRATION(a) | ||
: 1. Reactor Vessel Pressure | : 1. Reactor Vessel Pressure | ||
: 2. Reactor Vessel Water Level | : 2. Reactor Vessel Water Level | ||
: 3. Suppression Chamber Water Level | : 3. Suppression Chamber Water Level | ||
: 4. Suppression Chamber Water Temperature | : 4. Suppression Chamber Water Temperature | ||
: 5. Suppression Chamber Air Temperature Deleted | : 5. Suppression Chamber Air Temperature Deleted | ||
: 6. Primary Containment Pressure | : 6. Primary Containment Pressure | ||
: 7. Drywell Air Temperature Deleted | : 7. Drywell Air Temperature Deleted | ||
: 8. Deleted | : 8. Deleted | ||
: 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 | ||
Line 554: | Line 553: | ||
LIMERICK - UNIT 1 3/4 3-87 Amendment No. 116 , 173 , 179 , 186 TABLE 3.3.7.5-1 ACCIDENT MONITORING INSTRUMENTATION | 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 | MINIMUM APPLICABLE REQUIRED NUMBER CHANNELS OPERATIONAL INSTRUMENT OF CHANNELS OPERABLE CONDITIONS ACTION | ||
: 1. Reactor Vessel Pressure 2 1 1,2 80 | : 1. Reactor Vessel Pressure 2 1 1,2 80 | ||
: 2. Reactor Vessel Water Level 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 | : 3. Suppression Chamber Water Level 2 1 1,2 80 | ||
: 4. Suppression Chamber Water Temperature 8, 6 locations 6, 1,2 80 | : 4. Suppression Chamber Water Temperature 8, 6 locations 6, 1,2 80 | ||
1/location | 1/location | ||
: 5. Suppression Chamber Air Temperature Deleted 1 1 1,2 80 | : 5. Suppression Chamber Air Temperature Deleted 1 1 1,2 80 | ||
: 6. Drywell Pressure 2 1 1,2 80 | : 6. Drywell Pressure 2 1 1,2 80 | ||
: 7. Drywell Air Temperature Deleted 1 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 | ||
Line 574: | Line 573: | ||
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 | ||
: 3. Suppression Chamber Water Level | : 3. Suppression Chamber Water Level | ||
: 4. Suppression Chamber Water Temperature | : 4. Suppression Chamber Water Temperature | ||
: 5. Suppression Chamber Air Temperature Deleted | : 5. Suppression Chamber Air Temperature Deleted | ||
: 6. Primary Containment Pressure | : 6. Primary Containment Pressure | ||
: 7. Drywell Air Temperature Deleted | : 7. Drywell Air Temperature Deleted | ||
: 8. Deleted | : 8. Deleted | ||
: 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 | **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 |
Revision as of 23:33, 12 July 2019
ML071780293 | |
Person / Time | |
---|---|
Site: | Limerick |
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 No.ciancL50-353
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 1 OCFR 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 61 0-765-5529.
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 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
Subject:
Proposed Changes to Acci dent 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 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
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 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
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
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 Nu clear 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
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).
- 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 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
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
- 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
- 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