ML071760167

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License Amendments, Issuance of Amendment Incorporation of Revised 10 CFR Part 20 Requirements Into the Technical Specifications (TAC Nos. MD4946 and MD4947)
ML071760167
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 06/29/2007
From: Peter Bamford
NRC/NRR/ADRO/DORL/LPLI-2
To: Crane C
AmerGen Energy Co
Bamford, Peter J., NRR/DORL 415-2833
Shared Package
ml071760176 List:
References
TAC MD4946, TAC MD4947
Download: ML071760167 (16)


Text

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

SUBJECT:

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

MD4946 AND MD4947)

Dear Mr. Crane:

The Commission has issued the enclosed Amendment No. 187 to Facility Operating LicenseNo. NPF-39 and Amendment No. 148 to Facility Operating License No. NPF-85, for Limerick Generating Station, Units 1 and 2. This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated June 2, 2006.This amendment revises the TSs to incorporate revised requirements in Title 10 of the Code ofFederal Regulations, Part 20. Specifically, the amendment revises the definitions for Membersof the Public and Unrestricted Area, adds a definition for Restricted Area, revises the requirements for limitations on the concentrations of radioactive material released in liquid and gaseous effluents, and revises the references for radioactive effluent control requirements.A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in theCommission's biweekly Federal Register notice.Sincerely,/ra/ (John D. Hughey for)Peter Bamford, Project ManagerPlant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 187 to License No. NPF-39
2. Amendment No. 148 to License No. NPF-85
3. Safety Evaluationcc w/encls: See next page June 29, 2007Mr. Christopher M. CranePresident and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

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

MD4946 AND MD4947)

Dear Mr. Crane:

The Commission has issued the enclosed Amendment No. 187 to Facility Operating LicenseNo. NPF-39 and Amendment No. 148 to Facility Operating License No. NPF-85, for Limerick Generating Station, Units 1 and 2. This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated June 2, 2006.This amendment revises the TSs to incorporate revised requirements in Title 10 of the Code ofFederal Regulations, Part 20. Specifically, the amendment revises the definitions for Membersof the Public and Unrestricted Area, adds a definition for Restricted Area, revises the requirements for limitations on the concentrations of radioactive material released in liquid and gaseous effluents, and revises the references for radioactive effluent control requirements.A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in theCommission's biweekly Federal Register notice.Sincerely,/ra/ (John D. Hughey for)Peter Bamford, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-352 and 50-353

Enclosures:

1. Amendment No. 187 to License No. NPF-39
2. Amendment No. 148 to License No. NPF-85
3. Safety Evaluationcc w/encls: See next pageDISTRIBUTION:PUBLICLPLI-2 R/FRidsNrrDorlLplI-2RidsNrrPMPBamfordRidsNrrDorlDprGHill,OIS (4)EKeeganRidsNrrLAEWhittRidsNrrDirsItsbRidsOgsRpRidsRgn1MailCenterRidsAcrsAcnwMailCenterRidsNrrDirsIhpbAmendment Accession Number: ML071760167 Tech Spec Pages: ML071860404 (amd#187); ML071860406(amd#148); Package Accession Number: ML071760176OFFICELPLI-2/PMLPLI-2/PMLPL3-2/LANRR/ITSB/BCNRR/IHPB/BCOGCNRR/LPLI-2/BCNAMEJHugheyPBamfordEWhittTKobetzRPedersenDRothHChernoffDATE6/29/076/25/076/26/076/26/076/28/076/29/076/29/07OFFICIAL RECORD COPY Limerick Generating Station, Unit Nos. 1 and 2 cc:Site Vice PresidentLimerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464Plant ManagerLimerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464Regulatory Assurance Manager - LimerickExelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464Vice President - Operations, Mid-AtlanticExelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348Vice PresidentLicensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555DirectorLicensing and Regulatory Affairs Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348Manager LicensingLimerick Generating Station Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348Correspondence Control DeskExelon Generation Company, LLC P.O. Box 160 Kennett Square, PA 19348Regional Administrator, Region IU.S. Nuclear Regulatory Commission

475 Allendale Road King of Prussia, PA 19406Senior Resident InspectorU.S. Nuclear Regulatory Commission Limerick Generating Station P.O. Box 596 Pottstown, PA 19464Library U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Director, Bureau of Radiation ProtectionPennsylvania Dept. of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469ChairmanBoard of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468Dr. Judith JohnsrudNational Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803Associate General CounselExelon Generating Company, LLC 4300 Winfield Road Warrenville, IL 60555 Limerick Generating Station, Unit Nos. 1 and 2 cc:Mr. Christopher M. CranePresident & Chief Nuclear Officer Exelon Generating Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 EXELON GENERATION COMPANY, LLCDOCKET NO. 50-352LIMERICK GENERATING STATION, UNIT 1AMENDMENT TO FACILITY OPERATING LICENSEAmendment No. 187License No. NPF-391.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Exelon Generation Company, LLC (thelicensee), dated June 2, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-39 is hereby amended to read as follows: (2)Technical Specifications and Environmental PlanThe Technical Specifications contained in Appendix A and the EnvironmentalProtection Plan contained in Appendix B, as revised through Amendment No. , are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.3.This license amendment is effective as of its date of issuance and shall be implementedwithin 60 days of the date of issuance.FOR THE NUCLEAR REGULATORY COMMISSION/ra/Harold K. Chernoff, ChiefPlant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance: June 29, 2007 ATTACHMENT TO LICENSE AMENDMENT NO. 187FACILITY OPERATING LICENSE NO. NPF-39DOCKET NO. 50-352Replace the following page of the Facility Operating License with the revised page. The revisedpage is identified by amendment number and contains marginal lines indicating the areas ofchange.RemoveInsertPage 3Page 3Replace the following pages of the Appendix A Technical Specifications with the attachedrevised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. RemoveInsert1-41-41-71-7 1-81-8 6-14a6-14a 6-226-22 EXELON GENERATION COMPANY, LLCDOCKET NO. 50-353LIMERICK GENERATING STATION, UNIT 2AMENDMENT TO FACILITY OPERATING LICENSEAmendment No. 148License No. NPF-851.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Exelon Generation Company, LLC (thelicensee) dated June 2, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-85 is hereby amended to read as follows: (2)Technical Specifications and Environmental Protection PlanThe Technical Specifications contained in Appendix A and the EnvironmentalProtection Plan contained in Appendix B, as revised through Amendment No. , are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.3.This license amendment is effective as of its date of issuance and shall be implementedwithin 60 days of the date of issuance.FOR THE NUCLEAR REGULATORY COMMISSION/ra/Harold K. Chernoff, ChiefPlant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance: June 29, 2007 ATTACHMENT TO LICENSE AMENDMENT NO. 148FACILITY OPERATING LICENSE NO. NPF-85DOCKET NO. 50-353Replace the following page of the Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating theareas of change.RemoveInsertPage 3Page 3Replace the following pages of the Appendix A Technical Specifications with the attachedrevised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. RemoveInsert1-41-41-71-7 1-81-8 6-14a6-14a 6-226-22 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 187 TO FACILITY OPERATING LICENSE NO. NPF-39AND AMENDMENT NO. 148 TO FACILITY OPERATING LICENSE NO. NPF-85EXELON GENERATION COMPANY, LLCLIMERICK GENERATING STATION, UNITS 1 AND 2DOCKET NOS. 50-352 AND 50-35

31.0 INTRODUCTION

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

Units 1 and 2. The NRC staff's original proposed no significant hazards consideration determination was published in the Federal Register on April 10, 2007 (72 FR 17949).This amendment would revise the TSs to incorporate revised requirements in Title 10 of theCode of Federal Regulations (10 CFR), Part 20, "Standards for Protection Against Radiation." Specifically, the amendment would revise the definitions for Members of the Public and Unrestricted Area, add a definition for Restricted Area, revise the requirements for limitations on the concentrations of radioactive material released in liquid and gaseous effluents, and revise the references for radioactive effluent control requirements. Portions of this change are consistent with TS Task Force (TSTF) Change Traveler No. 258-A (TSTF-258-A), Rev. 4, "Changes to Section 5.0, Administrative Controls."

2.0 REGULATORY EVALUATION

The applicable regulatory requirements and guidelines for this License Amendment Request(LAR) are:1.10 CFR Part 20 2.10 CFR Part 50, Appendix I, "Numerical Guides for Design Objectives andLimiting Conditions for Operation to Meet the Criterion 'As Low As Is Reasonably Achievable' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents"3.10 CFR 50.36a, "Technical specifications on effluents from nuclear powerreactors"4.TSTF-258-A, Revision 4 5.NUREG-1433, Revision 3.0, "Standard Technical Specifications General ElectricPlants, BWR/4" 6.NUREG-1302, "Offsite Dose Calculation Manual Guidance: StandardRadiological Effluent Controls for Boiling Water Reactors."In 1994, 10 CFR Part 20 was updated. Implementation requirements were specified in10 CFR 20.1008. As part of this change, dose limits for individual members of the public resulting from plant operations, were reduced from 500 millirem/year to 100 millirem/year, total effective dose equivalent, as specified in 10 CFR 20.1301.In addition to the requirements in 10 CFR Part 20, controls over the content of licensee TSsrelating to radioactive effluents are specified in 10 CFR 50.36a. Section 50.36a of 10 CFR requires licensees to maintain control over radioactive material in gaseous and liquid effluentsreleased to unrestricted areas to levels that are as low as reasonably achievable (ALARA). For power reactors Appendix I to 10 CFR Part 50 contains numerical guides provided to meet the ALARA requirement. It specifies that the total quantity of radioactive material released from a site shall be such that it does not result in an estimated annual dose or dose commitment of more than 3 millirem total body or 10 millirem to any organ to an individual in an unrestricted area (liquid releases). It also specifies no more than 10 millirads gamma or 20 millirads beta for annual gaseous effluents. Thus Appendix I contains much more stringent radiological criteria than the regulatory limits specified in 10 CFR Part 20.Additionally, the allowable instantaneous dose rates normally specified in the plant TS foreffluents were chosen by the NRC staff to keep annual average releases of radioactive material in gaseous and liquid effluents to within the dose values specified in Appendix I of 10 CFR Part

50. As specified in NUREG-1302, values corresponding to a dose rate of 500 mrem/year have been shown to be acceptable as a TS limit for liquid effluents to establish a high likelihood that the Appendix I yearly ALARA criteria are met. Likewise limitations on gaseous effluents of 500 mrem/year to the total body, and 3000 mrem/year to the skin (from noble gases) as well as 1500 mrem/yr to any organ from Iodine-131, Iodine-133, tritium and all particulate radionuclides with half-lives greater than 8 days have also been shown to provide assurance of operation within the Appendix I criteria.Appendix B to 10 CFR Part 20 contains a tabulated listing of effluent concentrations (Table 2,columns 1 and 2) that correspond to concentrations which would result in a total effective dose equivalent of 50 mrem to a member of the public in an unrestricted area if continuously inhaled or ingested over the course of one year. One of the useful purposes of this table, in conjunction with criteria in the plant TSs, is to provide a means for a licensee to calculate an instantaneous release rate that may be applied to site effluents in order to conform to the TS effluent release rate controls listed above.

3.0 TECHNICAL EVALUATION

LGS, Unit 1 and Unit 2 have separate TS. The following changes are identical for both units. The licensee's proposed changes and NRC staff's evaluation of the changes, are discussed below.

3.1Definitions3.1.1 Proposed ChangesDefinition 1.22, "MEMBER(S) OF THE PUBLIC" will be revised to state: "Member of the Publicmeans any individual except when that individual is receiving an occupational dose."Definition 1.36a, "RESTRICTED AREA," will be added and state: "Restricted area means anarea, access to which is limited by the licensee for the purpose of protecting individuals against undue risk from exposure to radiation and radioactive materials. Restricted area does not include areas used as residential quarters, but separate rooms in a residential building may be set apart as a restricted area."Definition 1.45, "UNRESTRICTED AREA," will be revised to state: "Unrestricted Area meansan area, access to which is neither limited nor controlled by the licensee."3.1.2NRC Staff Evaluation Revising the definitions for the terms "MEMBER(S) OF THE PUBLIC" and "UNRESTRICTEDAREA," and adding the definition for "RESTRICTED AREA," make the LGS TS definitions consistent with the definitions provided in 10 CFR Part 20.The NRC staff finds that the change ensures consistency between the TS and the regulationswith no impact on the safety of the units or to members of the public and is therefore, acceptable.3.2TS Section 6.8.4.d.23.2.1Proposed Changes TS will be revised to read "10 times the concentration values in 10 CFR Part 20, Appendix B,Table 2, Column 2." 3.2.2 NRC Staff Evaluation The existing LGS TS for both Unit 1 and Unit 2 reference the old (pre-1994) 10 CFR Part 20,Appendix B, Table II, as a release rate control. This proposed change will replace thereference to the old 10 CFR Part 20, Appendix B, Table II with the revised 10 CFR Part 20, Appendix B, Table 2. The factor of 10 that is being applied to the 10 CFR Part 20, Appendix B, Table 2 effluent concentration values will maintain the same level of radioactive effluent control as had previously existed under the old 10 CFR Part 20, Appendix B, Table II reference. Paragraph 50.36a contains TS requirements regarding ALARA for liquid and gaseous effluentsand also allows the licensee the flexibility of allowing releases which temporarily permit higher doses as long as the licensee meets the annual dose limits in 10 CFR 20.1301 and the dose design objectives stated in 10 CFR Part 50, Appendix I.An instantaneous release concentration which corresponds to a dose rate of 500 mrem/year isacceptable as a TS limit for liquid effluents because the annual dose limits in 10 CFR 20.1301 and the dose design objectives in 10 CFR Part 50, Appendix I must still be met. By meeting thedose design objectives in 10 CFR Part 50, Appendix I, the doses are therefore considered ALARA. This change is intended to eliminate possible confusion or improper implementation of the 1994revised 10 CFR Part 20 requirements. It provides sufficient controls over instantaneous release rates to ensure that the annual dose guidelines of 10 CFR 50, Appendix I and the limits of 10 CFR 20.1301 will be met. On this basis, the NRC staff finds the proposed change acceptable.3.3TS Section 6.8.4.d.33.3.1Proposed Changes TS will be revised to reference "10 CFR 20.1302" instead of "10 CFR 20.106."

3.3.2NRC Staff Evaluation The 1994 revision of 10 CFR Part 20 replaced 10 CFR 20.106 with 10 CFR 20.1301 and10 CFR 20.1302. Section 20.1301 of 10 CFR contains the requirements for dose limits for individual members of the public, and 10 CFR 20.1302 contains the requirements for compliance with the dose limits. This change therefore provides a clear link between the TS and the required dose limits of 10 CFR Part 20. On this basis, the NRC staff finds the proposed change acceptable.3.4TS Section 6.8.4.d.73.4.1Proposed Changes TS will be revised to state the following:

"Limitations on the dose rate resulting from radioactive material released in gaseous effluentsfrom the site to areas at or beyond the SITE BOUNDARY shall be limited to the following:a.For noble gases: less than or equal to 500 mrem/yr to the total body and less than orequal to 3000 mrem/yr to the skin, andb.For iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-livesgreater than 8 days: less than or equal to 1500 mrem/yr to any organ."3.4.2NRC Staff Evaluation The existing LGS TS for both Unit 1 and Unit 2 reference the old (pre-1994) 10 CFR Part 20,Appendix B, Table II as a release rate control. This proposed change will replace the reference to the old 10 CFR Part 20, Appendix B, Table II with the revised 10 CFR Part 20, Appendix B, Table 2. The concentrations listed in the old 10 CFR Part 20, Appendix B, Table II are values based onmaximum permissible concentrations which relate to an annual dose of 500 mrem. The gaseous effluent concentration limits listed in the revised 10 CFR Part 20, Appendix B, Table 2 are based on an annual dose of 50 mrem for isotopes for which inhalation or ingestion is limiting or 100 mrem for isotopes for which submersion (noble gases) is limiting.Paragraph 50.36a contains the TS requirements regarding ALARA for liquid and gaseouseffluents and also allows the licensee the flexibility of allowing releases which temporarily permit higher doses as long as the licensee meets the annual dose limits in 10 CFR 20.1301 and the dose design objectives stated in 10 CFR Part 50, Appendix I.Release concentrations corresponding to limiting dose rates at the site boundary from noblegases less than or equal 500 mrem/year to the whole body and 3000 mrem/year to the skin, and less than or equal to 1500 mrem/year to any organ from Iodine-131, Iodine-133, for tritium and all radionuclides in particulate form with half-lives greater than eight days are acceptable as TS release rate controls for gaseous effluents to assure that the annual dose limits in 10 CFR 20.1301 and the dose design objectives stated in 10 CFR Part 50, Appendix I are not likely to be exceeded. This change is intended to eliminate possible confusion or improper implementation of therevised 10 CFR Part 20 requirements. It provides sufficient controls over instantaneous release rates to ensure that the annual dose guidelines of 10 CFR Part 50, Appendix I and the limits of 10 CFR 20.1301 will be met. On this basis, the NRC staff finds the proposed change acceptable. 3.5TS Section 6.14.1.a.23.5.1Proposed Changes TS will be revised to reference "10 CFR 20.1302" instead of "10 CFR 20.106."

3.5.2NRC Staff Evaluation The 1994 revision of 10 CFR Part 20 replaced 10 CFR 20.106 with 10 CFR 20.1301 and10 CFR 20.1302. Section 20.1301 of 10 CFR contains the requirements for dose limits for individual members of the public, and 10 CFR 20.1302 contains the requirements for compliance with the dose limits. This change therefore provides a clear link between the TS and the required dose limits of 10 CFR Part 20. On this basis, the NRC staff finds the proposed change acceptable

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. TheCommission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (72 FR 17949). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Principal Contributors:E. KeeganP. BamfordDate: June 29, 2007