ML051890035

License Amendment Request Proposed Changes to Extend the Use of Pressure-Temperature Limits Specified in Technical Specifications Figures 3.4.9-1, 3.4.9-2, and 3.4.9-3

ML051890035
Person / Time
Site:	Peach Bottom
Issue date:	07/06/2005
From:	Cowan P Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MB5192, TAC MB5193
Download: ML051890035 (18)

Text

el 10 CFR 50.90 July 6, 2005 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Unit 3 Renewed Facility Operating License No. DPR-56 NRC Docket No. 50-278

SUBJECT:

License Amendment Request Proposed Changes to Extend the Use of Pressure-Temperature Limits Specified in Technical Specifications Figures 3.4.9-1, 3.4.9-2, and 3.4.9-3

REFERENCES:

1. Letter from J. P. Boska, U S . NRC, to J. L. Skolds, Exelon Nuclear, Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendment RE: 1.62% Increase in Licensed Power Level (TAC Nos. MB5192 and MB5193), dated November 22,2002.

2. Letter from M. P. Gallagher, Exelon Nuclear, to U.S. NRC, Submittal of Peach Bottom Atomic Power Station, Units 2 & 3, Safety Analysis Report, Revision 1, Appendix K Measurement Uncertainty Recovery Power Uprate (License Amendment Request 01-01 190), dated September 24, 2002.

3. Letter from J. F. Klapproth, General Electric Company, to U. S. NRC, Submittal of GE Proprietary Document NEDC-32983P, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations, dated September 1, 2000.

4. Letter from S. A. Richards, U.S. NRC, to J. F. Klapproth, GE Nuclear Energy, Safety Evaluation for NEDC-32983P, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluation (TAC No. MA9891), dated September 14, 2001.

5. American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI, Case N-640, Alternative Reference Fracture Toughness for Development of P-T Limit CurvesSection XI, Division 1.I

6. American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI, Appendix G, 1995 Edition with addenda through the 1996 Addenda.

Pursuant to 10 CFR 50.90, Application for amendment of license or construction permit, Exelon Generation Company, LLC (Exelon), hereby requests a change to Renewed Facility Operating License No. DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Unit 3.

PBAPS Unit 3 P-T Curve LAR Docket No. 50-278 July 6, 2005 Page 2 In Reference 1, the NRC issued Amendment Nos. 247 and 250 to Facility Operating License Nos. DPR-44 and DPR-56 for PBAPS, Units 2 and 3, respectively. These amendments increased the licensed power level by approximately 1.62% from 3458 megawatts thermal (MWt) to 3514 MWt based on increased feedwater flow measurement accuracy achieved by utilizing high accuracy ultrasonic flow measurement instrumentation. In the case of PBAPS, Unit 3, Amendment No. 250 limited the use of the existing Unit 3 pressure-temperature (P-T) curves to 22 effective full power years (EFPY) based on the conclusions of General Electric (GE)

Safety Analysis Report NEDC-33064P, "Safety Analysis Report for Peach Bottom Atomic Power Station, Units 2 & 3, Thermal Power Optimization," Revision 1, dated September, 2002 (Attachment 1 to Reference 2) which indicated that, considering thermal power optimization conditions, the Unit 3 P-T curves become beltline limited at 22 EFPY and require modification for operation beyond 22 EFPY. This 22 EFPY limitation is not applicable to PBAPS, Unit 2, since the existing Unit 2 P-T curves are valid for 32 EFPY.

The proposed changes extend the use of the Unit 3 P-T limits specified in Technical Specifications (TS) Figure 3.4.9-1, "Temperature/Pressure Limits for lnservice Hydrostatic and lnservice Leakage Tests," Figure 3.4.9-2, "TemperaturelPressure Limits for Non-Nuclear Heatup and Cooldown Following Shutdown," and Figure 3.4.9-3, "Temperature/Pressure Limits for Criticality," from 22 EFPY to 32 EFPY.

In Reference 3, GE submitted a Licensing Topical Report (LTR) to the NRC describing a proposed methodology for calculating reactor vessel fast neutron fluence in Boiling Water Reactor (BWR) vessels. In Reference 4, the NRC found the GE methodology proposed in the LTR acceptable for referencing in licensing actions. Exelon has performed a bounding calculation of reactor vessel 32 EFPY fast neutron fluence for PBAPS, Unit 3, using the GE methodology. Revised P-T curves were then developed using this updated fluence calculation and American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (Code),Section XI, Case N-640 (Reference 5) and ASME Code,Section XI, Appendix G, paragraph G-2214.1 (Reference 6). A comparison of the revised P-T curves with the existing PBAPS, Unit 3 curves indicates that the existing curves are bounding through 32 EFPY.

Accordingly, Exelon requests that PBAPS, Unit 3, TS Figures 3.4.9-1, 3.4.9-2 and 3.4.9-3 be revised to extend the applicability of the existing P-T curves to 32 EFPY of operation. provides the evaluation of the proposed changes. Attachments 2 and 3 provide a copy of the marked up TS pages and typed TS pages, respectively, for the proposed changes.

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

PBAPS, Unit 3, is expected to reach 22 EFPY in late summer, 2006. Therefore, Exelon requests approval of the proposed amendment by July 6, 2006, with implementation within 60 days of issuance of the amendment, to ensure the validity of the P-T limitations and to support continued operation of PBAPS, Unit 3, beyond 22 EFPY.

There are no new regulatory commitments contained within this letter.

PBAPS Unit 3 P-T Curve LAR Docket No. 50-278 July 6, 2005 Page 3 The proposed changes have been reviewed by the Plant Operations Review Committee and approved by the Nuclear Safety Review Board.

Exelon is notifying the State of Pennsylvania of this application for a change to the TS by transmitting a copy of this letter and its attachments to the designated State Official.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 6th day of July 2005.

Respectfully, Pamela B. Cowan Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. Evaluation of the Proposed Changes

2. Technical Specifications Marked-up Pages

3. Technical Specifications Typed Pages cc: Regional Administrator - NRC Region I w/ attachments NRC Senior Resident Inspector - PBAPS 19 NRC Project Manager, NRR - PBAPS (1 Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection

ATTACHMENT 1 LICENSE AMENDMENT REQUEST PEACH BOTTOM ATOMIC POWER STATION, UNIT 3 DOCKET NO. 50-278 EVALUATION OF THE PROPOSED CHANGES

Subject:

Proposed Changes to Extend the Use of Pressure-Temperature Limits Specified in Technical Specifications Figures 3.4.9-1, 3.4.9-2, and 3.4.9-3 1.o DESCRIPTION 2.0 PROPOSEDCHANGES

7.0 REFERENCES

PBAPS Unit 3 P-T Curve LAR Attachment 1 Docket No. 50-278 Page 1 of 6 EVALUATION OF PROPOSED CHANGES 1.O DESCRIPTION Pursuant to 10 CFR 50.90, Application for amendment of license or construction permit, Exelon Generation Company, LLC (Exelon), hereby requests a change to Renewed Facility Operating License No. DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Unit 3.

The proposed changes extend the use of the Unit 3 pressure-temperature (P-T) limits specified in Technical Specifications (TS) Figure 3.4.9-1, Temperature/Pressure Limits for lnservice Hydrostatic and lnservice Leakage Tests, Figure 3.4.9-2, Temperature/Pressure Limits for Non-Nuclear Heatup and Cooldown Following Shutdown, and Figure 3.4.9-3, Temperature/Pressure Limits for Criticality, from 22 effective full power years (EFPY) to 32 EFPY.

In Reference 7.1, General Electric (GE) Company submitted a Licensing Topical Report (LTR) to the NRC describing a proposed methodology for calculating reactor vessel fast neutron fluence in Boiling Water Reactor (BWR) vessels. In Reference 7.2, the NRC found the GE methodology proposed in the LTR acceptable for referencing in licensing actions. Exelon has performed a bounding calculation of reactor vessel 32 EFPY fast neutron fluence for PBAPS, Unit 3, using the GE methodology. Revised P-T curves were then developed using this updated fluence calculation and American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (Code),Section XI, Case N-640 (Reference 7.3) and ASME Code,Section XI, Appendix G, paragraph G-2214.1 (Reference 7.4). A comparison of the revised P-T curves with the existing PBAPS, Unit 3 curves indicates that the existing curves are bounding through 32 EFPY. Accordingly, Exelon requests that PBAPS, Unit 3, TS Figures 3.4.9-1, 3.4.9-2 and 3.4.9-3 be revised to extend the applicability of the existing P-T curves to 32 EFPY of operation.

2.0 PROPOSED CHANGE

S PBAPS, Unit 3, TS Figure 3.4.9-1 will be changed to indicate that Curve A is valid for 32 EFPY of operation, and that the 32 EFPY beltline curve is less limiting than Discontinuity Curve A.

PBAPS, Unit 3, TS Figure 3.4.9-2 will be changed to indicate that curves B and BBHare valid for 32 EFPY of operations, and that the 32 EFPY beltline curve is less limiting than Discontinuity Curve B.

PBAPS, Unit 3, TS Figure 3.4.9-3 will be changed to indicate that Curve C is valid for 32 EFPY of operation, and that the 32 EFPY beltline curve is less limiting than Discontinuity Curve C.

3.0 BACKGROUND

In Reference 7.5, the NRC issued Amendment Nos. 247 and 250 to Facility Operating License Nos. DPR-44 and DPR-56 for PBAPS, Units 2 and 3, respectively. These amendments increased the licensed power level by approximately 1.62% from 3458 megawatts thermal (MWt) to 3514 MWt based on increased feedwater flow measurement accuracy achieved by utilizing high accuracy ultrasonic flow measurement instrumentation. In the case of PBAPS, Unit 3, Amendment No. 250 limited the use of the existing Unit 3 P-T curves to 22 EFPY based on the conclusions of GE Safety Analysis Report NEDC-33064P, Safety Analysis Report for

PBAPS Unit 3 P-T Curve LAR Attachment 1 Docket No. 50-278 Page 2 of 6 EVALUATION OF PROPOSED CHANGES Peach Bottom Atomic Power Station, Units 2 & 3, Thermal Power Optimization, Revision 1, dated September, 2002 (Attachment 1 to Reference 7.6) which indicated that, considering thermal power optimization conditions, the Unit 3 P-T curves become beltline limited at 22 EFPY and require modification for operation beyond 22 EFPY. PBAPS, Unit 3, is expected to reach 22 EFPY in late summer, 2006. Therefore, Exelon is requesting approval of this amendment to ensure the validity of the P-T limitations and to support continued operation of PBAPS, Unit 3, beyond 22 EFPY. This 22 EFPY limitation is not applicable to PBAPS, Unit 2, since the existing Unit 2 P-T curves are valid for 32 EFPY.

4.0 TECHNICAL ANALYSIS

In 2001, in support of the Thermal Power Optimization (TPO) Project, a bounding calculation of reactor vessel 32 EFPY fast neutron fluence was completed for PBAPS, Unit 3, using the GE methodology approved by the NRC in Reference 7.2, which adheres to the guidance in Regulatory Guide 1.190, Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence. The three-dimensional spatial distribution of neutron flux was modeled by combining the results of two separate two-dimensional neutron transport calculations. The cross section library used in the calculations is based on Version V of the Evaluated Nuclear Data File (ENDF/B-V). However, cross sections for the important components of BWR neutron flux calculation - oxygen, hydrogen, and individual iron isotopes -

have been upgraded to ENDFIB-VI to meet the guidelines of Regulatory Guide 1.190. In order to evaluate the neutron flux distribution that would bound the licensed power conditions for the PBAPS reactors, the operating condition assumed for the flux calculation was based on the projected Limerick Generating Station (LGS), Unit 2, Cycle 6 core data. The analysis inputs were based on the core design data generated by Global Nuclear Fuel - America (GNF-A). The LGS, Unit 2, Cycle 6 core load contained 544 bundles of GE13, 104 bundles of GE11, and 116 bundles of GE6 (Shoreham fuel). The 8x8 GE6 fuels are loaded solely into the peripheral zone of the core. The core power used was the currently licensed power of 3458 MWt. This approach yielded a flux value that bounded the flux determined from the PBAPS, Unit 3, flux wires by 76%.

To be conservative, it was also assumed that 5% power rerate conditions occurred from the first day of commercial operation (1974), rather than when the power rerate was actually implemented (1995). Additionally, it was confirmed that the calculated fluence value bounds the fluence value for the thermal power optimization level of 3514 MWt. The 32 EFPY peak fluence value at the vessel inside diameter (ID) was estimated to be 1.3E18 n/cm2as compared to the value of 7.2E17 nkm2that was generated from surveillance specimen measurements and used to develop the existing PBAPS, Unit 3, P-T curves. This bounding fluence calculation led to the conclusion that the PBAPS, Unit 3, P-T curves become beltline limited at 22 EFPY, and would require modification for operation beyond 22 EFPY.

Subsequently, the bounding reactor vessel fast neutron fluence value was used in concert with ASME Code Case N-640 and ASME Code,Section XI, Appendix G, paragraph G-2214.1 to develop updated P-T curves. The methodology used to develop the updated P-T curves is similar to the methodology used to generate the existing P-T curves, except the existing curves did not utilize the benefit of Code Case N-640 and ASME Code,Section XI, Appendix G, paragraph G-2214.1. A comparison of the updated P-T curves with the existing PBAPS, Unit 3 curves indicates that the existing curves are bounding through 32 EFPY. This provides

PBAPS Unit 3 P-T Curve LAR Attachment 1 Docket No. 50-278 Page 3 of 6 EVALUATION OF PROPOSED CHANGES sufficient assurance that the PBAPS, Unit 3 reactor vessel will be operated in a manner that will protect it from brittle fracture.

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. The proposed changes do not involve a significant hazards consideration for the following reasons:

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

Response: No. The proposed changes to the technical specifications to extend the use of the existing pressure-temperature (P-T) limits does not affect the operation or configuration of any plant equipment. Thus, no new accident initiators are created by this change. The proposed P-T limits are based on the projected reactor vessel neutron fluence at 32 effective full power years (EFPY) of operation. A bounding calculation of reactor vessel 32 EFPY fast neutron fluence has been completed for Peach Bottom Atomic Power Station (PBAPS), Unit 3, using the methodology described in a General Electric (GE) Company Licensing Topical Report (LTR), which adheres to the guidance in Regulatory Guide 1.190, Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence. The three-dimensional spatial distribution of neutron flux was modeled by combining the results of two separate two-dimensional neutron transport calculations. The latest available cross section libraries for the important components of Boiling Water Reactor (BWR) neutron flux calculations, i.e., oxygen, hydrogen and individual iron isotopes, were included. The resulting reactor vessel fast neutron fluence value was then used in concert with the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (Code),Section XI, Case N-640 and ASME Code,Section XI, Appendix G, paragraph G-2214.1 to develop updated P-T curves. A comparison of the updated P-T curves with the existing PBAPS, Unit 3 curves indicates that the existing curves are bounding through 32 EFPY. This provides sufficient assurance that the PBAPS, Unit 3, reactor vessel will be operated in a manner that will protect it from brittle fracture under all operating conditions.

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 to the technical specifications to extend the use of the existing P-T limits do not affect the operation or configuration of any plant equipment. The proposed P-T limits will remain valid and conservative throughout the proposed extension.

PBAPS Unit 3 P-T Curve LAR Attachment 1 Docket No. 50-278 Page 4 of 6 EVALUATION OF PROPOSED CHANGES Therefore, the proposed changes will 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 extend the use of the existing P-T limits. The proposed P-T limits are based on the projected reactor vessel neutron fluence at 32 EFPY of operation. A bounding calculation of reactor vessel 32 EFPY fast neutron fluence has been completed for PBAPS, Unit 3, using the NRC approved methodology in a GE LTR, which adheres to the guidance in Regulatory Guide 1.190. The three-dimensional spatial distribution of neutron flux was modeled by combining the results of two separate two-dimensional neutron transport calculations. The latest available cross section libraries for the important components of BWR neutron flux calculations, i.e.,

oxygen, hydrogen and individual iron isotopes, were included. The resulting reactor vessel fast neutron fluence value was then used in concert with ASME Code Case N-640 and ASME Code,Section XI, Appendix G, paragraph G-2214.1 to develop updated P-T curves. A comparison of the updated P-T curves with the existing PBAPS, Unit 3 curves indicates that the existing curves are bounding through 32 EFPY. This provides sufficient margin such that the PBAPS, Unit 3, reactor vessel will be operated in a manner that will protect it from brittle fracture under all operating conditions.

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

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 RequirementdCriteria The NRC has promulgated regulations to ensure the structural integrity of the reactor pressure vessel for light water power reactors. Specific fracture toughness requirements for normal operation and for anticipated operational occurrences for power reactors are set forth in Appendix G, Fracture Toughness Requirements, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities. These requirements are imposed through 10 CFR 50.60, Acceptance criteria for fracture prevention measures for light water nuclear power reactors for normal operation. Appendix G to 10 CFR Part 50 requires licensees to develop and utilize P-T limits in order to provide adequate margins of safety during any condition of operation, including anticipated operational occurrences and system hydrostatic tests, to which the pressure boundary may be subjected over its service lifetime. Appendix G to 10 CFR Part 50 incorporates by reference the editions of the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (Code),Section XI, Appendix G, through the 1995 Edition and addenda through the 1996 Addenda, as the basis of the requirements for RPV P-T limit methodology. Appendix G to 10 CFR Part 50 states that P-T limits: .must be at least as conservative as limits obtained I..

by following the methods of analysis and the margins of Appendix G of Section XI of the ASME Code.

PBAPS Unit 3 P-T Curve LAR Attachment 1 Docket No. 50-278 Page 5 of 6 EVALUATION OF PROPOSED CHANGES To satisfy the requirements of Appendix G and General Design Criterion (GDC) 14, Reactor Coolant Pressure Boundary, GDC 30, Quality of Reactor Coolant Pressure Boundary, and GDC 31, Fracture Prevention of Reactor Coolant Pressure Boundary, of Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50, methods for determining the fast neutron fluence (E > 1.O MeV) are necessary to estimate the fracture toughness of the pressure vessel materials. Appendix H, Reactor Vessel Material Surveillance Program Requirements, to 10 CFR Part 50 requires the installation of surveillance capsules, including material test specimens and flux dosimeters, to provide data on material damage correlations as a function of fluence.

GDC 31 of Appendix A to 10 CFR Part 50 requires, in part, that the reactor coolant pressure boundary be designed with sufficient margin to ensure that, when stressed under operating, maintenance, testing, and postulated accident conditions, (1) the boundary behaves in a non-brittle manner and (2) the probability of rapidly propagating fracture is minimized. GDC 31 also requires that the design reflect the uncertainties in determining the effects of irradiation on material properties. Appendix G and Appendix H to 10 CFR Part 50, which implement, in part, GDC 31, necessitate the calculation of changes in fracture toughness of reactor vessel materials caused by neutron radiation throughout the service life. NRC Regulatory Guide (RG) 1.99, Radiation Embrittlement of Reactor Vessel Materials, Revision 2, describes general procedures acceptable to the NRC staff for calculating the effects of neutron radiation embrittlement of the low-alloy steels currently used for light-water-cooled reactor vessels. The fracture toughness of pressure vessel materials is related to a parameter called the materials reference temperature for nil-ductility transition, or simply reference temperature, and is denoted as RTNDT.The RTNDT is defined in Revision 2 of RG 1.99 by a correlation of the neutron fluence (E > 1.O MeV),

material chemistry (concentrations of Copper and Nickel), initial reference temperature, and margin to account for uncertainties in the correlation and input values.

In March 2001, the NRC also issued RG 1.190, Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence, which was developed to provide state-of-the-art calculation and measurement procedures that are acceptable to the NRC for determining pressure vessel fluence. These methods are directly applicable to the determination of RTNDT. This RG ensures the accuracy and reliability of the fluence determination required by GDCs 14, 30, and 31 of Appendix A to 10 CFR Part 50 by providing standardized methods and procedures that improve confidence in the calculated fluence values based on the calculation and measurement improvements discussed above.

In Reference 7.1, GE submitted a Licensing Topical Report to the NRC describing a proposed methodology for calculating reactor vessel fast neutron fluence. The GE methodology employs an analytic approach based on the discrete ordinates neutron transport method to determine the fast (E>1 .O MeV) flux (and fluence) in BWR vessels, and adheres to the guidance in RG 1.190. The method uses available BWR surveillance capsule dosimetry measurements for the validation of the analytic transport calculations and the elimination of the uncertainty and bias. In Reference 7.2, the NRC found the GE methodology proposed in the LTR acceptable for referencing in licensing actions.

PBAPS Unit 3 P-T Curve LAR Attachment 1 Docket No. 50-278 Page 6 of 6 EVALUATION OF PROPOSED CHANGES In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

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 Part 20. 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(~)(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. Letter from J. F. Klapproth, General Electric Company, to U. S. NRC, Submittal of GE Proprietary Document NEDC-32983P, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations, dated September 1, 2000.

2. Letter from S. A. Richards, U.S. NRC, to J. F. Klapproth, GE Nuclear Energy, Safety Evaluation for NEDC-32983P, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluation (TAC No. MA9891), dated September 14, 2001.

3. American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI, Case N-640, Alternative Reference Fracture Toughness for Development of P Limit CurvesSection XI, Division 1 .I

4. American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI, Appendix G, 1995 Edition with addenda through the 1996 Addenda.

5. Letter from J. P. Boska, U S . NRC, to J. L. Skolds, Exelon Nuclear, Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendment RE: 1.62% Increase in Licensed Power Level (TAC Nos. MB5192 and MB5193), dated November 22,2002.

6. Letter from M. P. Gallagher, Exelon Nuclear, to U.S. NRC, Submittal of Peach Bottom Atomic Power Station, Units 2 & 3, Safety Analysis Report, Revision 1, Appendix K Measurement Uncertainty Recovery Power Uprate (License Amendment Request 01-01 190), dated September 24, 2002.

ATTACHMENT 2 LICENSE AMENDMENT REQUEST PEACH BOTTOM ATOMIC POWER STATION, UNIT 3 DOCKET NO. 50-278 PROPOSED CHANGES TO EXTEND THE USE OF PRESSURE-TEMPERATURE LIMITS SPECIFIED IN TECHNICAL SPECIFICATIONS FIGURES 3.4.9-1,3.4.9-2, AND 3.4.9-3 MARKED-UP TECHNICAL SPECIFICATIONS PAGES FOR THE PROPOSED CHANGE Unit 3 TS Paqes 3.4-25 3.4-26 3.4-27

RCS P/T Limits 3.4.9 Figure 3 . 4 . 9 - 1 ( p a g e 1 o f 1)

Tempera t u r e / P r e s s u r e Limi t s f o r I n s e r v i c e H y d r o s t a t i c a n d I n s e r v i c e Leakage T e s t s PBAPS UNIT 3 3.4-25 Amendment No, 250

RCS P / T Limits 3.4.9 I

I Figure 3.4.9-2 ( p a g e 1 o f 1)

Temperature/Pressure Limits f o r N o n - N u c l e a r Heatup and Cooldown F o l l o w i f i g a Shutdown PBAPS UNI T 3 3.4-26 Amendment No ~ 250

RCS P / T L i m i t s 3.4.9 Figure 3.4.9-3 (page 1 of 1)

Temperature/Pressure Limits f o r Criticality

'BAPS UNIT 3 3.4-27 Amendment No. 250

ATTACHMENT 3 LICENSE AMENDMENT REQUEST PEACH BOTTOM ATOMIC POWER STATION, UNIT 3 DOCKET NO. 50-278 PROPOSED CHANGES TO EXTEND THE USE OF PRESSURE-TEMPERATURE LIMITS SPECIFIED IN TECHNICAL SPECIFICATIONS FIGURES 3.4.9-1,3.4.9-2, AND 3.4.9-3 TYPED TECHNICAL SPECIFICATIONS PAGES FOR THE PROPOSED CHANGE Unit 3 TS Paaes 3.4-25 3.4-26 3.4-27

R C S P/T L i m i t s 3.4.9 1600 1400 1200 1GOO EG 0 EUO 400 200 0

F i g u r e 3 . 4 . 9 - 1 (page 1 o f 1 )

Temperature/Pressure L i m i t s f o r I n s e r v i c e H y d r o s t a t i c and I n s e r v i c e Leakage T e s t s PBAPS UNIT 3 3.4-25 Amendment No.

RCS P/T Limits 3.4.9 0 100 200 300 4-06 530 600 MINIMUM REACTOR VE5SEL ME%L TEEMPEFtATU3f (OF)

Figure 3.4.9-2 (page 1 o f 1)

Temperature/Pressure Limits for Non-Nuclear Heatup and Cooldown Following a Shutdown PBAPS UNIT 3 3.4-26 Amendment No.

RCS P / T Limits 3.4.9 7 500 7 4.80 Ln CL W

i20.8 4GO 2fro F i g u r e 3 . 4 . 9 - 3 ( p a g e 1 o f 1)

Temperature/Pressure L i m i t s f o r C r i t i c a l i t y PBAPS UNIT 3 3.4-27 Amendment No.