ML19213A246

License Amendment Request - Proposed Relocation of Chlorine and Toxic Gas Detection System Technical Specifications

ML19213A246
Person / Time
Site:	Limerick
Issue date:	08/01/2019
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML19213A246 (27)

Text

10 CFR 50.90 August 1, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

License Amendment Request - Proposed Relocation of Chlorine and Toxic Gas Detection System Technical Specifications In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively.

The proposed changes relocate the following operability and surveillance requirements from the LGS TS to the LGS Technical Requirements Manual (TRM):

• TS Section 3.3.7.8.1, "Chlorine Detection System, and

• TS Section 3.3.7.8.2, Toxic Gas Detection System.

Associated with the relocation of the Chlorine Detection System requirements, Surveillance Requirement 4.7.2.1.e.2, that requires verifying that the Control Room Emergency Fresh Air System automatically switches to the chlorine isolation mode upon a chlorine actuation signal (provided by the Chlorine Detection System), is proposed to be relocated to the TRM in conjunction with the relocated Chlorine Detection System instrumentation requirements.

The proposed changes conform to the requirements of 10 CFR 50.36, Technical specifications, for the contents of TS, and are consistent with the improved Standard Technical Specifications issued by the NRC in NUREG-1433, Standard Technical Specifications - General Electric BWR/4 Plants.

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

The proposed changes have been reviewed by the LGS Plant Operations Review Committee in accordance with the requirements of the Exelon Quality Assurance Program.

License Amendment Request Relocation of Chlorine and Toxic Gas Detection Systems Docket Nos. 50-352 and 50-353 August 1, 2019 Page 2 This amendment request contains no regulatory commitments. provides the evaluation of the proposed changes. Attachment 2 provides a copy of the marked up TS pages that reflect the proposed changes. Attachment 3 provides a copy of the marked up TS Bases pages that reflect the proposed changes (for information only).

Exelon requests approval of the proposed amendments by August 1, 2020. Upon NRC approval, the amendments shall be implemented within 60 days of issuance.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the Commonwealth of Pennsylvania of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

Should you have any questions concerning this submittal, 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 1st day of August 2019.

Respectfully, James Barstow Director, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes

2. Markup of Proposed Technical Specifications Pages

3. Markup of Proposed Technical Specifications Bases Pages (For Information Only) cc: Regional Administrator - NRC Region I w/ attachments NRC Senior Resident Inspector - Limerick Generating Station NRC Project Manager, NRA - Limerick Generating Station Director, Bureau of Radiation Protection - Pennsylvania Department 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 Relocation of Chlorine and Toxic Gas Detection System Technical Specifications 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedence 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

License Amendment Request Attachment 1 Relocation of Chlorine and Toxic Gas Detection Systems Page 1 of 10 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively.

The proposed changes relocate the following operability and surveillance requirements from the LGS TS to the LGS Technical Requirements Manual (TRM):

• TS Section 3.3.7.8.1, "Chlorine Detection System, and

• TS Section 3.3.7.8.2, Toxic Gas Detection System.

In accordance with LGS Updated Final Safety Analysis Report (UFSAR), Section 13.5.3 (Reference 1), the TRM is a licensee-controlled procedure described in the UFSAR and, therefore, changes to the TRM are subject to the requirements of 10 CFR 50.59, Changes, tests and experiments. Accordingly, any future changes to Chlorine Detection System and Toxic Gas Detection System operability and surveillance requirements will be controlled in accordance with the requirements of 10 CFR 50.59.

Associated with the relocation of the Chlorine Detection System requirements, Surveillance Requirement (SR) 4.7.2.1.e.2, that requires verifying that the Control Room Emergency Fresh Air System (CREFAS) automatically switches to the chlorine isolation mode upon a chlorine actuation signal (provided by the Chlorine Detection System), is proposed to be relocated to the TRM in conjunction with the relocated Chlorine Detection System instrumentation requirements.

The proposed changes conform to the requirements of 10 CFR 50.36, Technical specifications (Reference 2), for the contents of TS, and are consistent with the improved Standard Technical Specifications issued by the NRC in NUREG-1433, Standard Technical Specifications - General Electric BWR/4 Plants (Reference 3).

2.0 DETAILED DESCRIPTION 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. The NRC subsequently adopted an amendment to 10 CFR 50.36, Technical specifications, (60 FR 36953, July 19, 1995; Reference 5) to codify and incorporate these criteria. The criteria are restated below.

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

License Amendment Request Attachment 1 Relocation of Chlorine and Toxic Gas Detection Systems Page 2 of 10 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes Criterion 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.

Criterion 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.

Criterion 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 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. In accordance with LGS UFSAR Section 13.5.3 (Reference 1), the TRM is a licensee-controlled procedure described in the UFSAR and, therefore, changes to the TRM are subject to the requirements of 10 CFR 50.59.

Accordingly, any future changes to Chlorine Detection System and Toxic Gas Detection System operability and surveillance requirements will be controlled by 10 CFR 50.59.

Additionally, the nuclear steam supply system owners' groups and the NRC staff developed improved Standard Technical Specifications (STS) that established 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.

The changes requested by this amendment application, based on the criteria specified in the NRC Final Policy Statement, the requirements of 10 CFR 50.36 and the guidance provided in NUREG-1433, are described below.

1. TS Index, page ix for LGS, Units 1 and 2, under Section 3/4.3.7, Monitoring Instrumentation, will be revised to replace the titles Chlorine Detection System and Toxic Gas Detection System, with words Deleted; refer to note on page.

2. TS Section 3.3.7.8.1, on TS page 3/4 3-90 for LGS, Units 1 and 2, will be deleted in its entirety. Page 3/4 3-90 will indicate Section 3/4.3.7.8.1 (Deleted), and will state that the information from this TS section has been relocated to the TRM.

3. TS Section 3.3.7.8.2, on TS page 3/4 3-91 for LGS, Units 1 and 2, will be deleted in its entirety. Page 3/4 3-91 will indicate Section 3/4.3.7.8.2 (Deleted), and will state that the information from this TS section has been relocated to the TRM.

4. TS Section 3.7.2 on TS page 3/4 7-8 for LGS, Units 1 and 2, will be revised to replace the SR 4.7.2.1.e.2 text with the phrase Relocated to the TRM.

The marked-up pages that reflect the proposed changes are provided in Attachment 2 (TS pages) and Attachment 3 (TS Bases pages - information only). Prior to implementation of the amendment, relocated requirements for the Chlorine Detection System and Toxic Gas Detection System will be incorporated into the LGS TRM as indicated above. Any subsequent changes to

License Amendment Request Attachment 1 Relocation of Chlorine and Toxic Gas Detection Systems Page 3 of 10 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes the LGS TRM requirements will be performed in accordance with 10 CFR 50.59 and station procedures.

3.0 TECHNICAL EVALUATION

The proposed license amendment relocates the Chlorine Detection System and Toxic Gas Detection System operability and surveillance requirements and Surveillance Requirement 4.7.2.1.e.2, that requires verifying that the Control Room Emergency Fresh Air System (CREFAS) automatically switches to the chlorine isolation mode upon a chlorine actuation signal (provided by the Chlorine Detection System), from the LGS TS to the LGS TRM. In accordance with LGS UFSAR, Section 13.5.3, the TRM is a licensee-controlled document with changes controlled as a procedure described in the LGS UFSAR and, therefore, changes are subject to the requirements of 10 CFR 50.59. The TRM has been used to capture and control other previously relocated TS requirements.

As discussed previously, the NRC 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.

An assessment of the subject Chlorine and Toxic Gas Detection Systems and the Chlorine Isolation Mode of CREFAS against the four criteria of 10 CFR 50.36 is provided below.

The Chlorine and Toxic Gas Detection Systems ensure that an accidental chlorine and/or toxic gas release will be detected promptly, and the necessary protective actions will be automatically initiated for chlorine and manually initiated for toxic gas to provide protection for control room personnel. Upon detection of a high concentration of chlorine, the control room emergency ventilation system will automatically be placed in the chlorine isolation mode of operation to provide the required protection. Upon detection of a high concentration of toxic gas, the control room emergency ventilation system will manually be placed in the chlorine isolation mode of operation to provide the required protection. The detection systems are consistent with the recommendations of Regulatory Guide 1.95, "Protection of Nuclear Power Plant Control Room Operators against an Accidental Chlorine Release," February 1975.

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

This criterion addresses instrumentation installed to detect excessive reactor coolant system (RCS) leakage. LGS TS Sections 3.3.7.8.1, 3.3.7.8.2, and SR 4.7.2.1.e.2 do not cover installed instrumentation that is used to detect and indicate in the control room, a significant degradation of the reactor coolant pressure boundary. The Chlorine and Toxic Gas Detection Systems ensure that an accidental chlorine and/or toxic gas release will be detected promptly, and the necessary protective actions will be automatically initiated for chlorine and manually initiated for toxic gas to provide protection for control room personnel. Therefore, the Chlorine Detection System, Toxic Gas Detection System, and Chlorine Isolation Mode of CREFAS do not satisfy Criterion 1.

License Amendment Request Attachment 1 Relocation of Chlorine and Toxic Gas Detection Systems Page 4 of 10 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes Criterion 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.

The purpose of this criterion is to capture those process variables that have initial values assumed in the design basis accident and transient analyses, and that are monitored and controlled during power operation. This criterion also includes active design features (e.g., high-pressure/low-pressure system valves and interlocks) and operating restrictions (pressure/temperature limits) needed to preclude unanalyzed accidents and transients.

The Chlorine and Toxic Gas Detection Systems ensure that an accidental chlorine and/or toxic gas release will be detected promptly, and the necessary protective actions will be automatically initiated for chlorine and manually initiated for toxic gas to provide protection for control room personnel. These detection systems do not involve process variables that have initial values assumed in the design basis accident and transient analyses, and that are monitored and controlled during power operation. Therefore, the Chlorine Detection System, Toxic Gas Detection System, and Chlorine Isolation Mode of CREFAS do not satisfy Criterion 2.

Criterion 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.

The purpose of this criterion is to capture only those structures, systems, and components that are part of the primary success path of the safety analysis (an examination of the actions required to mitigate the consequences of the design basis accident and transients). The primary success path of a safety analysis consists of the combinations and sequences of equipment needed to operate so that the plant response to the design basis accident and the transients limits the consequences of these events to within the appropriate acceptance criteria. Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function, but the criterion does not include backup and diverse equipment.

The Chlorine and Toxic Gas Detection Systems ensure that an accidental chlorine and/or toxic gas release will be detected promptly, and the necessary protective actions will be automatically initiated for chlorine and manually initiated for toxic gas to provide protection for control room personnel. These detection systems do not function or actuate 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. Therefore, the Chlorine Detection System, Toxic Gas Detection System, and Chlorine Isolation Mode of CREFAS do not satisfy Criterion 3.

Criterion 4: A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The purpose of this criterion is to capture only those structures, systems, and components that operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

License Amendment Request Attachment 1 Relocation of Chlorine and Toxic Gas Detection Systems Page 5 of 10 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes The Chlorine and Toxic Gas Detection Systems ensure that an accidental chlorine and/or toxic gas release will be detected promptly, and the necessary protective actions will be automatically initiated for chlorine and manually initiated for toxic gas to provide protection for control room personnel. The Chlorine Detection System, Toxic Gas Detection System, and Chlorine Isolation Mode of CREFAS are not a structure, system, or component that operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

A review of industry operating experience did not produce any examples where the failure of the Chlorine Detection System, Toxic Gas Detection System, and Chlorine Isolation Mode of CREFAS had a significant adverse effect on public health and safety.

In the Severe Accident Risk Assessment (SARA) for LGS submitted to the NRC in 1983 (Reference 6), toxic releases were included as a hazard group. The scope included the chemicals monitored by the toxic gas and chlorine detectors. This included the onsite storage of chlorine gas and vinyl chloride from a nearby chemical plant in the scope of the hazard.

The results of that analysis showed that the core damage risk was 6.3E-08 (Section 7.1.7 of Reference 6). This is less than the other analyzed hazards groups (i.e., internal events, internal flooding, seismic and fire), and thus, would not be considered significant to public health and safety.

The review of the SARA by the NRC in NUREG/CR-3493 (Reference 7) was limited to seismic and fire hazard groups because they are the dominant contributors to risk. This reinforces that the environmental hazards monitored by the toxic gas and chlorine detection systems are not a significant contributor to risk.

Since the time of the SARA report, the site has ceased using gaseous chlorine for water treatment and the fixed offsite source (Hooker Chemical in the SARA) has ceased operation, further reducing the contribution to risk by these systems.

In addition, the Chlorine Detection System, Toxic Gas Detection System, and Chlorine Isolation Mode of CREFAS are not modeled in the LGS probabilistic risk assessment.

Therefore, the Chlorine Detection System, Toxic Gas Detection System, and Chlorine Isolation Mode of CREFAS do not satisfy Criterion 4.

The requirements contained in the TS Sections 3.3.7.8.1, 3.3.7.8.2 and TS SR 4.7.2.1.e.2 do not meet any of the 10 CFR 50.36(c)(2)(ii) criteria for items that must be in the TS. In addition, 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. NUREG-1433 does not contain any operability or surveillance requirements for the Chlorine or Toxic Gas Detection Systems or the Chlorine Isolation Mode of the Main Control Room Environmental Control System.

The proposed changes do not alter the physical design of any plant structure, system, or component; therefore, the proposed changes have no adverse effect on plant operation, or the availability or operation of any accident mitigation equipment. The plant response to the design

License Amendment Request Attachment 1 Relocation of Chlorine and Toxic Gas Detection Systems Page 6 of 10 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes basis accidents does not change. The proposed changes do not require any new or unusual operator actions. The proposed changes do not introduce any new failure modes that could result in a new accident. There is no change being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed changes.

Therefore, the Chlorine Detection System and Toxic Gas Detection System operability and surveillance requirements, and the Surveillance Requirement for testing actuation of the Chlorine Isolation Mode of CREFAS, may be relocated to the TRM.

TS Bases Sections B 3/4.3.7.8 The TS Bases for the Chlorine Detection System (TS Section 3/4.3.7.8.1) and the Toxic Gas Detection System (TS Section 3/4.3.7.8.2) contained in TS Bases Section B 3/4.3.7.8, Chlorine and Toxic Gas Detection Systems, will be relocated to the TRM. Changes to the TRM will be made to reflect the proposed changes to the respective TS. The marked up TS Bases pages that reflect the proposed changes are provided in Attachment 3 for information purposes only.

4.0 REGULATORY EVALUATION

4.1 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.

Section 50.36c(2)(ii) of Title 10 of the Code of Federal Regulations (10 CFR 50.36c(2)(ii))

contains the requirements for items that must be in TS. This regulation provides the four criteria that can be used to determine the requirements that must be included in the TS.

A TS limiting condition for operation (LCO) of a nuclear reactor must be established for each item meeting one or more of the following criteria:

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 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.

Criterion 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.

License Amendment Request Attachment 1 Relocation of Chlorine and Toxic Gas Detection Systems Page 7 of 10 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes Criterion 4: A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

Items not meeting any of these four criteria can be relocated from the TS to a licensee-controlled document. The licensee can then change the relocated requirements, if necessary, in accordance with 10 CFR 50.59.

The NRC published improved Standard Technical Specifications in NUREG-1433. The TS requirements proposed for relocation do not meet the four screening criteria, and therefore, are not included in NUREG-1433. Operability and surveillance requirements for the Chlorine Detection System and Toxic Gas Detection System and SR 4.7.2.1.e.2 will be maintained in a licensee-controlled document (i.e., the LGS TRM), such that future changes could be made to these provisions pursuant to 10 CFR 50.59.

4.2 Precedence A similar change, to relocate the operability and surveillance requirements for the Chemical Detection Systems from TS to a licensee-controlled document, was approved by the NRC by issuance of Amendment Nos. 76 and 65 for South Texas Project, Units 1 and 2, respectively, by letter dated July 6, 1995 (Reference 8).

4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of the Renewed Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS),

Units 1 and 2, respectively.

The proposed changes relocate certain operability and surveillance requirements for the Chlorine Detection System and Toxic Gas Detection System and Surveillance Requirement 4.7.2.1.e.2, that requires verifying that the Control Room Emergency Fresh Air System automatically switches to the chlorine isolation mode upon a chlorine actuation signal (provided by the Chlorine Detection System), from the LGS TS to a licensee-controlled document.

The proposed changes conform to the requirements of 10 CFR 50.36, Technical specifications, for the contents of TS, and are consistent with the improved Standard Technical Specifications issued by the NRC in NUREG-1433, Standard Technical Specifications - General Electric BWR/4 Plants.

Exelon has evaluated the proposed changes, using the criteria in 10 CFR 50.92, Issuance of amendment, and has determined that the proposed changes do not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.

License Amendment Request Attachment 1 Relocation of Chlorine and Toxic Gas Detection Systems Page 8 of 10 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes

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

Response: No The proposed changes do not alter the physical design of any plant structure, system, or component; therefore, the proposed changes have no adverse effect on plant operation, or the availability or operation of any accident mitigation equipment. The plant response to the design basis accidents does not change.

Operation or failure of the Chlorine Detection System and the Toxic Gas Detection System are not assumed to be initiators of any analyzed event in the Updated Final Safety Analysis Report (UFSAR) and cannot cause an accident. Whether the requirements for the Chlorine Detection System and the Toxic Gas Detection System are in TS or another licensee-controlled document has no effect on the probability or consequences of any accident previously evaluated.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed changes do not alter the plant configuration (no new or different type of equipment is being installed) or require any new or unusual operator actions. The proposed changes do not alter the safety limits or safety analysis assumptions associated with the operation of the plant. The proposed changes do not introduce any new failure modes that could result in a new accident. The proposed changes do not reduce or adversely affect the capabilities of any plant structure, system, or component in the performance of their safety function.

Also, the response of the plant and the operators following the design basis accidents is unaffected by the proposed changes.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No The proposed changes have no adverse effect on plant operation, or the availability or operation of any accident mitigation equipment. The plant response to the design basis accidents does not change. The proposed changes do not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analyses. There is no change being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed changes.

License Amendment Request Attachment 1 Relocation of Chlorine and Toxic Gas Detection Systems Page 9 of 10 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above evaluation, Exelon concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (c), and accordingly, a finding of no significant hazards consideration is justified.

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

5.0 ENVIRONMENTAL CONSIDERATION

Exelon 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, "Standards for Protection Against Radiation." 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, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review,"

paragraph (c)(9). Therefore, pursuant to 10 CFR 51.22, paragraph (b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Limerick Generating Station, Updated Final Safety Analysis Report, Section 13.5.3, "Operations Technical Requirements Manual (TRM)."

2. 10 CFR 50.36, Technical Specifications.

3. NUREG-1433, Standard Technical Specifications-General Electric BWR/4 Plants, Revision 4.0, dated April 2012.

4. NRC Final Policy Statement on Technical Specifications Improvements 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).

License Amendment Request Attachment 1 Relocation of Chlorine and Toxic Gas Detection Systems Page 10 of 10 Docket Nos. 50-352 and 50-353 Evaluation of Proposed Changes

6. Limerick Generating Station Severe Accident Risk Assessment, Philadelphia Electric Company, April 1983.

7. NUREG/CR-3493, A review of the Limerick Generating Station Severe Accident Risk Assessment, USNRC, July 1984.

8. Letter from T. W. Alexion (USNRC) to W. T. Cott, Houston Lighting & Power Company, South Texas Project, Units 1 and 2 - Amendment Nos. 76 and 65 to Facility Operating License Nos. NPF-76 and NPF-80 (TAC Nos. M91611 and M91612), dated July 6, 1995.

ATTACHMENT 2 License Amendment Request Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 Proposed Relocation of Chlorine and Toxic Gas Detection System Technical Specifications Markup of Proposed Technical Specifications Pages Unit 1 TS Pages ix 3/4 3-90 3/4 3-91 3/4 7-8 Unit 2 TS Pages ix 3/4 3-90 3/4 3-91 3/4 7-7

l IMITING CONDITIONS FOR OPERATION AND SURVEil LANCE REQUIREMENTS SECTION INSTRUMENTATION (Continued)

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PLANT SYSTEMS SURVEILLANCE REQUIREMENTS <Continued)

e. In accordance with the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the combined prefilte r, upstream and downstream HEPA filters, and charcoal adsorber banks is less than 6 inches water gauge while operating the subsystem at a flow rate of 3000 cfm +/- 10%; verifyin g that the prefilte r pressure drop is less than 0.8 inch water gauge and that the pressure drop across each HEPA is less than 2 inches water gauge.

2.

3. Verifying that on each of the below radiatio n isolatio n mode actuatio n test signals, the subsystem automatically switches to the radiatio n isolatio n mode of operatio n:

a) Outside air intake high radiatio n, and b) Manual initiatio n from control room.

f. After each complete or partial replacement of a HEPA filter bank by verifyin g that the HEPA filter bank satisfie s the inplace penetra-tion and bypass leakage testing acceptance criteria of less than 0.05%

in accordance with ANSI N510-1980 while operatin g the system at a flow rate of 3000 cfm +/- 10%.

g. After each complete or partial replacement of a charcoal adsorber bank by verifyin g that the charcoal adsorber bank satisfie s the inplace penetrat ion and bypass leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a halogenated hydrocarbon refriger ant test gas while operatin g the system at a flow rate of 3000 cfm +/- 10%.

4.7.2.2 The control room envelope boundary shall be demonstrated OPERABLE:

a. At a frequency in accordance with the Control Room Envelope Habitab ility Program by performance of control room envelope unfilter ed air inleakag e testing in accordance with the Control Room Envelope Habitab ility Program.

LIMERICK - UNIT 1 3/4 7-8 Amendment No. ;,~.+l-,+44,--1&9,

~. 188

INDEX LIMITING coNDITIONS FOR OPERATION . ANIJ :suRVE*ILLANCE .REOUIREMENTS

) .. *.

SECTION :

INSTR~MEN~ATION *; (Ccinti.~ued}:

• ; *. *  :' ... :**:

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' *;_.,_:

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• DELETED ; Ref er to note on. page< ..... *...... :*.. : ...* ; . ; : .... 3/ 4' 3~92 LIMERICK - UNIT 2 ix Amendment No . .U, J-9, eg, :/!J, -147

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LIMERICK - UNIT 2 3/4 3-90 Amendment No. JJ, J4, 147

INSTRUMENTATION ubsystems *noperabl of at le t one co orine iso ation mod

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LIMERICK - UNIT 2 3/4 3-91 Amendment No. J4, ~. 147

PLANT SYSTEMS SlJRVEI LLANCE REOU IREMENTS CContinued)

2. Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration of less than 2.5%

when tested in accordance with ASTM 03803 -1989 at a temperature of 30°C (86°F) and a relative humidity of 70%.

3. Verifying a subsystem flow rate of 3000 cfm +/- 10% during subsystem operation when tested in accordance with ANSI N510-1980.

d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a repre-sentative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration of less than 2.5% when tested in accordance with ASTM 03803-1989 at a temperature of 30°C (86°F) and a relative humidity of 70%.

e. In accordance with the Surveillance Frequency Control Program by:

1. Verifying that the pressure drop across the combined prefilter, upstream and downstream HEPA filters, and charcoal adsorber banks is less than 6 inches water gauge while operating the subsystem at a flow rate of 3000 cfm +/- 10%; verifying that the prefilter pressure drop is less than 0.8 inch water gauge ~nd that the pressure drop across each HEPA is less than 2 inches water gauge.

3. Verifying that on each of the below radiation isolation mode actuation test signals, the subsystem automatically switches to the radiation isolation mode of operation:

a) Outside air intake high radiation, and b) Manual initiation from control room.

LIMERICK - UNIT 2 314 7-7 Amendment No. J4, .f..Qe., -+/-47, 149

ATTACHMENT 3 License Amendment Request Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 Proposed Relocation of Chlorine and Toxic Gas Detection System Technical Specifications Markup of Proposed Technical Specifications Bases Pages (For Information Only)

Unit 1 TS Bases Pages xix B 3/4 3-6 Unit 2 TS Bases Pages xix B 3/4 3-6

)

BASES SECTION INSTRUMENTATION (Continued)

(Deleted) .... . ...... . ....... . .......... .. ........... ....... B 3/4 3-5

<Deleted) ........... ........... ........... ........... ...... B 3/4 3-5 Remote Shutdown System Instrumentation and Controls ........ B 3/4 3-5 Accident Monitoring Instrumentation . ...... . ........... ..... B 3/4 3-5 Source Range Monitors .. ........... ........... . . ..... ... .... B 3/4 3-5 (Deleted) ........... ........... ........... ........... ...... B 3/4 3-6 6+.l erifle afle! TeKi c '5ali Cit9~ti eR Sy stems ........... ........ B 3/4 3-6 (Deleted) ........... ........... ........... ........... ...... B 3/4 3-6 (Deleted) ........... ... ........... .......... . ... . .......... B 3/4 3-7 (Deleted) ........... ........... ........... ........... ...... 8 3/4 3-7 (Deleted) ........... ........... .... ... ........... .......... 8 3/4 3-7 3/4.3.8 (Deleted) ........... . ........... . ........... ........... ..... B 3/4 3-7 3/4.3.9 FEEDWATER/MAIN TURBINE TRIP SYSTEM ACTUATION INSTRUMENTATION ....... . ........... ........... .... . ......... B 3/4 3-7 Bases Figure B 3/4.3-1 Reactor Vessel Water Level ........... ........... . B 3/4 3-8 3/4.4 REACTOR COOLANT SYSTEM 3/4.4.1 RECIRCULATION SYSTEM ........... .... . ........... ........... . B 3/4 4-1 3/4 . 4.2 SAFETY/RELIEF VALVES ........... ........... ........... ...... B 3/4 4*2 3/4.4.3 REACTOR COOLANT SYSTEM LEAKAGE Leakage Detection Systems ........... ........... ........... . B 3/4 4-3 Operational Leakage . ... ........... . . ........... . . .......... B 3/4 4- 3 3/4.4.4 CHEMISTRY ........... ...... . .... .. ........... ........... .... 8 3/4 4-3

. -- - * - UMERr-CK - UNIT 1 xix Amendment No. ~, J, @, +-1,

-W4,W,m ,~.228

INSTRUMENTATION 3/4.3.7.9 <Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE TRM.

LIMERICK - UNIT 1 B 3/4 3-6 Amendment No. 4&.~.~.~.~.++/-+.186

~

• '* Bases Figure !f 3/4~3~1

• Reacto;. V~ssel *water .*.*

"" ... Level ....*.. *.. , ... ~, ............. .

• 3/ 4. 4*. REACTOR. COOLANT SY STEM **.

3/4.4.L .*RECIRCULATION.SYSTEM *.** ;;........... ........... ........... ,;

3/4. 4. 2 .* SAFETYlRELI EFVALVES ......* ..... ; **..* ; ...... ~ ......... ; .** , **

3/4:.4.3 . ***: REACTO~;COOLANTSYSTEWLEAKAGE :,*  : .,.

. Leakage Detection* Syst~ms .. ; . : ; ; ..... ~ .... ~.: .... ; ....... ; . B 3)4 4-.3

. Operati~nal Leakage--.*:.; ... : ... ~ .... ;.~.: .... .'; ... :.;;".*;-.* ... B 3/4 4~3.'~*. *-

3/4.4.4 ' .CHEMISTRY* .*. : ........... .... '..: ........... ...... ; ......**.** . B 3/44-3a .

LIMERICK - UNIT 2 xix Amendment No. M, ~. +7, ~.

J-9,~.+9.~.w. 191

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- INFORMATION FROM THIS SECTION RELOCATED TO THE TRM.

3/4.3.7.9 <Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE TRM.

LIMERICK - UNIT 2 B 3/4 3-6 Amendment No. +l- , ~,JJ.~,~.-79. 147