Text

License Amendment Request to Adopt TSTF-423, Risk Informed Modification to Selected Required Action End States for BWR Plants. Using the Consolidated Line Item Improvement Process
	ML061950597
Person / Time
Site:	Peach Bottom
Issue date:	07/14/2006
From:	Cowan B; Exelon Generation Co, Exelon Nuclear
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML061950597 (139)
	v • d • e

Exelon Nuclear www.exeloncorp.co~

2 0 0 Exelon ~

a y

Kennett Square, PA 19348 1 OCFR50.90 July 14, 2006 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

License Amendment Request to Adopt TSTF-423, Risk Informed ~odification to Selected Required Action End States for BWR Plants, Using the Consolidated Line Item Improvement Process Pursuant to 1 OCFR50.90, Application for amendment of license or construction permit, Exelon Generation Company, LLC (EGC) hereby requests an amendment to Appendix A, Technical Specifications (TS), of the Renewed Facility Operating Licenses listed above. The proposed amendment would modify TS to risk-inform requirements regarding selected Required Action End States. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. The proposed change would revise the TS requjrements related to required end states for TS action statements. The change is generally consistent with NRC-approved TSTF-423, Revision 0, Risk Informed Modification to Selected Required Action End States for BWR Plants. The availability of this TS Improvement was published in the Federal Reaister on March 23, 2006 as part of the consolidated line item improvement process (CLIIP). Enclosure 2 provides the existing TS pages marked up to show the proposed change. Enclosure 3 provides the existing TS Bases pages marked up to show the proposed change. Enclosure 3 is provided for information only. Enclosure 4 provides a summary of the regulatory commitments made in this submittal.

The subject changes are generally consistent with the changes outlined in TSTF-423, Revision

0. Minor differences between the proposed changes and those of TSTF-423, Revision 0 are described in Enclosure 1. While the PBAPS Units 2 and 3 TS are based on NUREG-1433, they are not identical to NUREG-1433. Therefore, adaptation of TSTF-423, Revision 0 was required.

Docket Nos. 50-277 and 50-278 Adopt TSTF-423, Risk Informed Modification to Selected Required Action End States for BWR Plants July 14, 2006 Page 2 EGC requests approval of the proposed license amendment by January 31, 2007, with the amendment being implemented within 120 days of approval.

The proposed change has been reviewed by the Plant Operations Review Committee and approved by the Nuclear Safety Review Board.

In accordance with 10 CFR 50.91, EGC is notifying the Commonwealth of Pennsylvania of this application for changes to the TS by transmitting a copy of this letter and its enclosures to the designated State Official.

If you have any questions or require additional information, please contact Mr. Dave Robillard at (61 0) 765-5952.

I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, Executed on Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC : Description of Proposed Changes, Technical Analysis, and Regulatory Analysis : Marked-up Technical Specification Pages : Marked-up Technical Specification Bases Pages : List of Regulatory Commitments cc:

S. J. Collins, Administrator, Region I, USNRC F. L. Bower, USNRC Senior Resident Inspector, Peach Bottom J. Kim, Project Manager, USNRC R. R. Janati, Commonwealth of Pennsylvania

ENCLOSURE 1 Description of Proposed Changes, Technical Analysis and Regulatory Analysis

1.0 DESCRIPTION

2.0 ASSESSMENT

2.1 Applicability of Topical Report, TSTF-423 and Published Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination 3.2 Verification and Commitments 4.0 ENVIRONMENTAL EVALUATION

5.0 REFERENCES

ENCLOSURE 1 DESCRIPTION OF PROPOSED CHANGES, TECHNICAL ANALYSIS AND REGULATORY ANALYSIS

1.0 DESCRIPTION

The proposed amendment would modify Technical Specifications (TS) to risk-inform requirements regarding selected Required Action End States.

The changes are generally consistent with the Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) TSTF-423, Revision 0. The availability of this TS Improvement was published in the Federal Register on March 23, 2006 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT

2.1 Applicability of Topical Report, TSTF-423 and Published Safety Evaluation Exelon Generation Company, LLC (EGC) has reviewed GE topical report (Reference 1), TSTF-423 (Reference 2), and the NRC model safety evaluation (Reference 3) as part of the CLIIP.

EGC has concluded that the information in the GE topical report and TSTF-423, as well as the safety evaluation prepared by the NRC staff are applicable to Peach Bottom Atomic Power Station (PBAPS) Unit Nos. 2 and 3 and justify this amendment for the incorporation of the changes to the PBAPS Unit Nos. 2 and 3 TS.

2.2 Optional Changes and Variations EGC is not proposing any variations or deviations from the GE topical report and the TS changes described in the TSTF-423, Revision 0, or the NRC staffs model safety evaluation dated March 23, 2006.

The proposed TS changes are generally consistent with TSTF-423, Revision 0. Minor differences between the proposed changes and those contained in TSTF-423, Revision 0 include:

Changes were made to several paragraphs and Section numbers because the TSTF was written based on NUREG-1433. While the PBAPS Units 2 and 3 TS are based on NUREG-1433, they are not identical to NUREG-1433. Therefore, adaptation of TSTF-423, Revision 0 was required.

The following Standard TS (STS) sections are not applicable to the PBAPS Unit Nos. 2 and 3 TS, and therefore are not part of this submittal:

3.6.1.6 Low-Low Set (LLS) Valves 3.6.1.9 Main Steam Isolation Valve (MSIV) Leakage Control System (LCS) 3.7.5 Control Room Air Conditioning (AC) System 3.8.7 Inverters -Operating Additionally, the following PBAPS Unit Nos. 2 and 3 TS sections did not require revision as a result of submitting the amendment request, because the existing TS required end states are already in conformance with the changes proposed in TSTF-423, Revision 0:

Description of Proposed Changes, Technical Analysis and Regulatory Analysis Page 2 of 3 3.3.8.2 Reactor Protection System (RPS) Electric Power Monitoring 3.4.3 Safety/Relief Valves (S/RVs) 3.7.2 Emergency Service Water (ESW) and Normal Heat Sink

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination EGC has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. EGC has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to PBAPS Unit Nos. 2 and 3 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on March 23, 2006 for this TS improvement, plant-specific verifications were performed as follows:

EGC commits to the regulatory commitments in Enclosure 4. In addition, EGC has proposed TS Bases consistent with the GE topical report and TSTF-423, which provide guidance and details on how to implement the new requirements. Implementation of TSTF-423 requires that risk be managed and assessed, and the licensees configuration risk management program is adequate to satisfy this requirement. The risk assessment need not be quantified, but may be a qualitative assessement of the vulnerability of systems and components when one or more systems are not able to perform their asociated function. Finally, EGC has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications (STS).

4.0 ENVIRONMENTAL EVALUATION The amendment changes requirements 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. The NRC staff has determined that the amendment adopting TSTF-423, Revision 0, 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 the individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that TSTF-423, Revision 0, involves no significant hazards considerations, and there has been no public comment on the finding in the Federal Register Notice 70 FR 74037, December 14, 2005. 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.

5.0 REFERENCES

1.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required Action End States for BWR Plants, December 2002.

2.

TSTF-423, Revision 0, Technical Specifications End States, NEDC-32988-A.

Description of Proposed Changes, Technical Analysis and Regulatory Analysis Page 3 of 3

3.

Federal Register, Vol. 71, No. 56, p. 14726, Notice of Availability of Model Application Concerning Technical Specifications for Boiling Water Reactor Plants to Risk-Inform Requirements Regarding Selected Required Action End States Using the Consolidated Line Item Improvement Process, and NRC Model Safety Evaluation, March 23, 2006.

ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION Changes ARK-UP)

UNIT 2 3.5-1 3.5-2 3.5-3 3.5-1 2 3.6-1 3.6-1 9 3.6-21 3.6-27 3.6-29 3.6-34 3.6-40 3.6-41 3.7-1 3.7-2 3.7-7 3.7-8 3.7-1 0 3.8-5 3.8-29 3.8-43 UNIT 3 3.5-1 3.5-2 3.5-3 3.5-1 2 3.6-1 3.6-1 9 3.6-21 3.6-27 3.6-29 3.6-34 3.6-40 3.6-41 3.7-1 3.7-2 3.7-7 3.7-8 3.7-1 0 3.8-5 3.8-29 3.8-43

ECCS -Ope r a t i ng 3.5.1 1 A. 1 Restore low p r e s s u r e ECCS i n j e c t i o n / s p r a y subsystem(s) t o OPERABLE s t a t u s.

3.5 E M E R ~ E N ~ Y CORE COOLING SYSTEMS ( E C C S ) AND REACTOR CORE ISOLATION COOLING

( R C I C ) SYSTEM 3.5.1 ECCS-Opera ti ng LCO 3.5.1 Each ECCS i n j e c t i o n / s p r a y subsystem and t h e Automatic D e p r e s s u r i z a t i o n System (ADS) f u n c t i o n o f f i v e s a f e t y / r e l i e f valves s h a l l be OPERABLE.

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - N O T E - - - - - - - - - - - - - - - - - - - - - - - - - - - -

Low pressure c o o l a n t i n j e c t i o n (LPCI) subsystems may be considered OPERABLE d u r i n g alignment and o p e r a t i o n f o r decay heat removal w i t h r e a c t o r steam dome p r e s s u r e l e s s t h a n t h e Residual Heat Removal (RHR) shutdown c o o l i n g i s o l a t i o n pressure i n MODE 3, i f capable o f b e i n g manually r e a l i g n e d and n o t o t h e r w i s e i n o p e r a b l e.

APPLICABILITY:

MODE 1, MODES 2 and 3, except h i g h pressure c o o l a n t i n j e c t i o n ( H P C I )

i s n o t r e q u i r e d t o be OPERABLE w i t h r e a c t o r steam dome pressure I 150 p s i g and ADS v a l v e s a r e n o t r e q u i r e d t o be OPERABLE w i t h r e a c t o r steam dome pressure r; 100 p s i g.

ACTIONS CON0 I T I ON REQUIRED ACTION COMPLETION TIME A.

One l o w pressure ECCS i n j e c t i o n h p r a y subsystem i n o p e r a b l e.

One low p r e s s u r e c o o l a n t i n j e c t i o n (LPCI) pump i n each subsystem i n o p e r a b l e.

7 days B.

Required A c t i o n and 8. 1 Be i n MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time o f C o n d i t i o n A n o t met.

I I

PBAPS UNIT 2 3.5-1

( c o n t i n u e d )

Amendm~nt No.

ECCS-Operating 3.5.1 ACTIONS (continued)

COND I T I ON C.

HPCl System i noperabl e.

Do HPCI System i noperabl e One low pressure ECCS i n j ec t i on/s pray subsystem is inoperable.

One ADS valve i

noperabl e.

REQUIRE^ ACTION C.1 Verify by administrative means RCIC System is OPERABLE.

AND c.2 Restore HPCI System to OPERABLE status, D. 1 Restore WPCI System to OPERABLE status,

212, 1.2 Restore low pressure ECCS injection/spray subsystem t o OPERABLE status.

CO~PLETION TIME

~

Immediately 14 days 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months r2 hours Restore ADS valve t o OPERABLE status, 14 days I

1 (continued)

PBAPS UNIT 2 3 5-2 Amendment No,

ECCS-Operat ing 3.5.1 ACTIONS (continued)

C ~ ~ ~ I ~ I O ~

One ADS valve i noperabl e, AND One low pressure ECCS inject i on/spray subsys tem i noperabl e.

H.

Two or more ADS valves i noperabl e.

1.

Two or more low pressure ECCS injection/spray subsystems inoperable for reasons other than Condition A.

HPCI System and one or more ADS valves inoperable.

REQUIRED ACTION Restore ADS valve t o OPERABLE status, Restore 1 ow pressure ECCS inject i on/spray subsystem t o OPERABLE status.

H. 1 Be i n MODE 3.

pg!

i.2 Reduce reactor steam dome pressure t o s 100 psig.

01 Enter LCO 3.0.3.

CO~PLETIO~

TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours lmmedi ately I

i.

G. Required Action and associated Completion Time of Condition C, D, E or F not met G.l Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months PBAPS UNIT 2 3.5-3 Amendment No.

R C I C System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOL IN^

( R C I C ) SYSTEM 3.5.3 R C I C System LCO 3.5.3 The R C I C System s h a l l be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 w i t h r e a c t o r steam dome p r e s s u r e > 150 p s i g.

ACTIONS

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - _ - - - - - N O T E - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

LCO 3.0.4.b i s n o t a p p l i c a b l e t o R C I C.

CONDITION A.

R C I C System i noperabl e.

B.

Required A c t i o n and associated Completion Time n o t met.

REQUIRED ACTION COMPLETION TIME A. 1 V e r i f y by Immediately a d m i n i s t r a t i v e means High Pressure Cool a n t I n j e c t i o n System i s OPERABLE.

AND A.2 Restore R C I C System 14 days t o OPERABLE s t a t u s.

B. 1 Be i n MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months PBAPS U N I T 2 3.5-12 Amendment No.

Primary Containment 3.6.1.1

- -~

COND IT ION 3.6 C O ~ T A I ~ ~ E ~ T SYSTEMS 3.6 0 1 1 Primary Containment REQUIRED ACTION CO~PLETION TIME LCO 3.6.1.1 Primary containment sball be OPERABLE, APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS A.

Primary containment i noperabl e.

A. 1 Restore primary containment to OPERABLE. status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

~

B.

Required Action and Be in MODE 3.

associ ated Compl eti on Time not met.

PBAPS UNIT 2 3.6-1 Amendment No.

Reactor Bui Jding-to-Suppression Chamber Vacuum Breakers 3.6.1.5 ACTIONS (~o~tinued)

CONDITION REQUIRE^ ACTION Two lines with one or Restore all vacuum more reactor building-to-suppression chamber to OPERABLE status.

vacuum breakers i

noperabl e for openi ng.

breakers i n one line Required Action and Assoc i ated Completion I

1 Be i n MODE 3.

Time &not met.

I&@

Be in MODE 4.

CO~P~ETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 12 hours 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIRE ME^^

S U R V E I L ~ N ~ E FREQUENCY SR 3.6.1.5.1 Verify Containment Atmospheric Dilution (CAD) System nitrogen storage tank 1 eve1 is z 16 inches water column.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.6.18582 Verify Safety Grade Instrument Gas (SGIG)

System header pressure 2 80 psig.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months D. Required Action and a~sociated Completion Time of Condition C not met.

D.1 Be in MODE 3.

PBAPS UNIT 2 3.6-19 Amendment No.

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 ITION ION 3.6 CONTAIN~E~T SYSTEMS REQUIRED ACTION 3.6.1.6 Suppression ~hamber-to~Drywel7 Vacuum Breakers LCO 3.6. li.6 Nine suppression ~hamberoto=dr~ell vacuum breakers shall be OPERABLE for open i ng.

Twelve suppression chamberotogdryweJl vacuum breakers shall be closed, except when performing their intended function.

APPLICABILITY:

MODES 1, 2, and 3.

A. One required Restore one required suppression charnber-vacuum breaker to to-drywell vacuum OPERABLE status.

breaker inoperable for opening.

One suppression charnber-to-drywell vacuum breaker not Close the open vacuum Required Action and as soc i at ed Compl et i on Be in MODE 4.

Ca~PLETIO~

TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 10 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours PBAPS UNIT 2 3. 6-21 Amendm~nt No.

RHR Suppression Pool Cooling 3.6.2.3 3.6 C O ~ T A I N ~ E ~ T SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be O P E ~ ~ L E.

APPLI~AB~LITY: MODES 1, 2, and 3.

ACT IONS I

PBAPS UNIT 2 3.6-27 Amendment No.

RHR Suppression Pool Spray 3.6.2.4 3.6 CO~TAIN~ENT SYSTEMS 3.6.2.4 Residual Heat Removal (RHR) Suppress i on Pool Spray LCO 3.6.2.4 Two RHR suppression pool spray subsystems shall be OPERABLE.

APPLICABI~ITY: MODES 1, 2, and 3, ACTIONS CONDITION A. One RHR suppression pool spray subsystem i noperabl e.

B.

Two RHR suppression pool spray subsystems i noperabl e.

C.

Required Action and associated Completion Time not met.

PBAPS UNIT 2

~

~-

RQUIRED ACTION A. 1 Restore RHR suppression pool spray subsystem to OPERABLE status, B, 1 Restore one RHR suppression pool spray subsystem to OPERABLE status.

c. 1 Be in MODE 3.

7 days 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 12 hours 3.6-29 A ~ e n d m ~ n t No,

Secondary Containment 3.6.4.1 3.6 CONTAIN~ENT SYSTEMS 3.6.4,1 Secondary ~ontain~ent LCO 3.6.4,l The secondary containment shall be OPERABLE.

APPLI~ABILITY: MODES 1, 2, and 3, During ~ o v e ~ n t o f irradiated fuel assemblies in the secondary containment,

During CORE A L T E ~ T I O ~ S,

During operations with a potential for draining the reactor vessel (OPDRVs)

ACTIONS A. Secondary containment inoperable in MODE 1, 2, or 3.

B. Required Action and associated Completion Time o f Condition A not met.

c.

Secondary contain~nt i noperabl e duri ng

~ o v e ~ e n t o f irradiated fuel assemblies in the secondary c ~ n t a i n ~ n t,

during CORE A l T E ~ T ~ O N S or during OPDRVs.

- _ _ _ _ _ ~

REQUIRED ACTION A. 1 Restore secondary containment to OPERABLE status.

B J Be in MODE 3, Suspend ~ovement o f irradiated fuel assemblies in the secondary contain~ent.

C O M P L E T ~ ~ ~

TIME 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 12 hours Imedi ately (continued)

PBAPS UNIT 2 3, 6-34 Amendment No.

SGT System 3.6.4.3 3.6 ~ ~ ~ T A I ~ ~ E ~ T SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems shall be OPERABLE.

APPLICA~ILITY: ~ D E S 1, 2, and 3, During movement o f irradiated fuel assemblies in the During CORE ALTE~TIONS, During operations with a potential for draining the reactor secondary containment, vessel (OPD~Vs).

ACTIONS CONDITION A.

One SGT subsystem inoperable.

8. Required Action and associated Completion Time o f Condition A not met in MODE 1, 2, or 3.

C.

Required Action and associated Completion Time o f Condition A not met during move~ent o f irradiated fuel assemblies in the secondary Containment, during CORE ALTE~TIONS, or during OPDRVs.

REQUIRED ACT ION A. 1 Restore SGT subsystem t o OPERABLE status.

B.1 Be i n MODE 3.

*- NOTE--..----------

LCO 3.0.3 i s not applicable.

c.1 Place OPERABLE SGT subsystem i n operation.

OR PBAPS UNIT 2 3.6-40 COMPLETION TIME 7 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately (cont i nued)

~ e n d ~ e n t No.

SGT System 3.6.4.3 I

ACT I ONS D J CON0 I T I ON C.

(continued) 0, Two SGT subsystems inoperable in MODE 1, 2, or 3.

E.

Two SGT subsystems inoperable during movement o f irradiated fuel assemblies in tht secondary containment, during CORE ALTE~TIONS, or during OPDRVs.

REQUIRE^ ACTION C.2.1 Suspend movement o f irradiated fuel assembl i es i n secondary containment.

C,2.2 Suspend CORE A L T E ~ T I O ~ S.

C.2.3 Initiate action to suspend OPDRVs.

Suspend movement o f irradiated fuel assembl i es in secondary containment.

AND E.2 Suspend CORE A L T E ~ T I O ~ S.

E.3 Initiate action to suspend OPDRVs.

I COMPLETION TIME fmmedi ately fmmedi ately Immediately Immedi ately Immediately

[mmedi ately I

PBAPS UNIT 2 3.6-41 Amendment No.

HPSW System 3.7*1 3.7 PLANT SYSTEMS 3.7-1 High Pressure Service Water (HPSW) System LCO 3.7.1 Two XPSW subsystems shall be OPERABLE.

APPLICABILITY:

MDES 1, 2, and 3.

ACTIONS CONDITl[ON A.

One HPSW subsystem i noperabl e.

. Both HPSW subsystems i

noperabl e.

R E ~ U I R E ~

ACTION oo---o----- NOTE-------------

Enter appl i cab7 e Condi t i ons and Required Actions o f LCO 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by HPSW System, I - - - - - - ~ - - - - I - - - - - ~ - - - - ~ - * - -

A. 1 Restore HPSW subsystem to OPERABLE status

.----*"-*** NOTE------I------

Enter applicable Conditions and Required Actions o f LCU 3.4.7 for RfiR shutdown cooling made inoperable by HPSW System.

Restore one HPSW subsystem t o OPERABLE

status, C O ~ P L E T I O ~

TIME 7 days 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

HPSW System 3.7.1 C O ~ D r T I O ~

REQU I RED ACT I ON C O ~ P L ~ I O ~

TIME Required Action and associated Compl eti on SURVEILLANCE SR 3.7.1.1 Verify each HPSW manual and power operated valve in the flow path, that is not locked, sealed, or otherwise secured in position, is i n the correct position or can be aligned to the correct position.

1 Be in MODE 3.

FREQUENCY 31 days PBAPS UNIT 2 3.7-2 Amendment No.

MCREV System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Main Control Room Emergency Ventilation (~CREV) System LCO 3.7.4 Two MCREV subsystems shall be OPERABLE.

APPLICABILIT~: MODES 1, 2, and 3, During ~ v e m e n t o f irradiated fuel assemblies in the During CORE ALTE~TIONS, During operations with a potential for draining the reactor secondary containment, vessel (OPDRVs).

ACTIONS A.

One. MCREV subsystem i noperabl e.

6, Required Action and associated Completion Time o f Condition A not met in MODE 1, 2, or 3.

C.

Required-Action and associated ~ o m p ~ e t j o ~

Time o f Condition A not net during movem~nt o f irradiated fuel assemblies in the secondary containment, during CORE ALTE~TIONS, or during OPDRVs.

REQUIRED ACTION A. 1 Restore MCREV subsystem to OPERABLE status.

B. 1 Be in MODE 3.

c. 1 PJace O P E ~ B L E MCREV subsystem in operation.

COMPLETION TIHE 7 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately (continued)

PBAPS UNIT 2 Amendment No.

MCREV System 307.4 ACTIONS CONDITION C.

(continued)

D.

Two MCREV subsystems inoperable in MODE 1, 2, or 3.

E.

Two MCREV subsystems i noperabl e during movement o f i rradi ated fuel assemblies in the secondary containment, during CORE ALTE~TIONS, or during OPDRVs.

REQUI~ED ACTION C.2.1 Suspend move~ent o f irradiated fuel assemblies in the secondary containment.

C.2.2 Suspend CORE ALTEMTIONS.

AND C2.3 Initiate action to suspend OPDRVs D.1 0

E. 1 Suspend movement o f irradiated fuel assembl ies in the secondary containment.

WD

.2 Suspend CORE A L T E ~ T I O ~ S

+

.3 Initiate action to suspend OPORVs.

COMPLETION TIME Immediately Immediately Immediately imedi ately

mmedi ately mmedi ately PBAPS UNIT 2 3.7-8 A~endment No,

Main Condenser Offgas 3.7.5 3.7 PLANT SYSTEMS 3 -7.5 Main Condenser Offgas Leo 3 - 7 3 The gross gamma activity rate o f the noble gases measured at the steam jet air ejector (SJAE) discharge at the offgas sample rack shall be s 320,000 /rCi/second after decay o f 30 minutes.

A P P L I C A ~ I ~ I T Y : MODE 1, MODES 2 and 3 with any main steam line not isolated and SJAE i n operation.

ACTIONS CONDITION A,

Gross gamma activity rate o f the noble gases not within

limit, B,

Required Action and associated Completion Time not met, REQUIRED ACT I ON A. 1 Restore gross gamma activity rate of the noble gases to within

limit, B.1 Isolate all main steam lines.

B.2 Isolate SJAE.

8.3 Be i n MODE 3, COMPLTIO~ TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 12 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours PBAPS UNIT 2 3.7-10 Amendm~nt No.

AC Sources-Operating 3.8.1 ACTIONS (continued~

CONDIT f ON E.

One offsite circuit inoperable.

AND One DG inoperable.

F. Two or more DGs inoperable.

G.

Required Action and associ ated Compl et i on Time of Condition A, C, 0, E, or F not met.

Required Action 8.2, 8.3, 8.4.1, 8.4.2, or 6.5 and associated Completion Time not met.

PBAPS UNIT 2 REQUIRED A ~ T I O ~

1.1.--------

NOTE --..---------.

Enter appl i cab1 e Condi t i ons and Required Actions o f LCO 3.8.7, "Distribution Systems-Operating, " when Condition E is entered with no AC power source to any 4 kV emergency bus,

- * - - - - - - -. - - - - I ~ - - - - ~ ~ - - o - ~ ~ -

E. 1 Restore o f f s i te circuit to OPERABLE status.

OR E.2 Restore DG to OPERABLE s t a t u s.

F. 1 Restore a71 but one DG t o OPERABLE status.

i. 1 Be i n MODE 3.

CO~PLETIO~

TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 12 hours (continued) 3.8-5 A ~ e n d m ~ n t No.

DC Sources-Operating 3.8.4 REQU I RED ACT1 ON ACTIONS (continued)

CON0 I T I ON CO~PLETION TIME B.

One Unit 3 DC electrical power subsystem inoperable for reasons other than Condition A.

C. One Unit 2 DC electrical power subsystem inoperable.

MOTE------------

Enter appficable Conditions and Required Actions o f LCO 3.8.7, "Distribution Systems --Opera t i ng, " when Condition B results in de-energization o f a Unit 2 4 kV emergency bus, B. 1 Restore Unit 3 DC el ectri cat power subsystem to OPERABLE status.

I 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

. 1 Restore Unit 2 DC el ectri cal power subsystem to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months D.

Required Action and Associ ated Compl et i on Time o f Condition A, 6, or C not met.

I D.1 Be in MODE 3.

I 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E.

Two or more inoperable E.1 Enter LCO 3.0.3.

I DC electrical power subsystems.

Immediately I

I PBAPS UNIT 2 3.8-29 Amendment No.

Distribution Systems-Operating 3.8.7 ACTIONS (continued)

COND IT I ON

0. One Unit 2 DC electrical power distribution subsystem inoperable.

E.

Required Action and associated Completion Time o f Condition A, B, C, or D not met.

F.

Two or more inoperable electrical power di str i but i on subs at result in a function.

REQUIRED ACTION D. 1 Restore Unit 2 DC electrical power distribution subsystem to OPERABLE status.

E. 1 Be i n MODE 3.

F. 1 Enter LCO 3.0.3.

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.7.1 Verify:

a.

Correct breaker a1 ignments to required AC electrical power distribution subsystems; and

b.

Indicated power availability to required AC and DC electrical power distribution subsystems.

CO~PLETION TIME 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND I6 hours from discovery o f failure to meet LCO 3.8.7.a 112 hours0.0013 days 0.0311 hours 1.851852e-4 weeks 4.2616e-5 months Immediately FREQUENCY 7 days PBAPS UNIT 2 3.8-43 Amendment No.

ECCS-Operating 3.5.1 I CO~PLETION TIME 3.5 E M E R G E ~ C Y CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATIO~ COOLI~G 3.5.1 ECCS-Operati ng

( R C I C ) SYSTEM LCO

3.5.1 APPLICABILITY

ACTIONS Each ECCS i n j e c t i o n / s p r a y subsystem and t h e Automatic D e p r e s s u r i z a t i o n System (ADS) f u n c t i o n o f f i v e s a f e t y / r e l i e f v a l v e s s h a l l be OPERABLE.

- - - - - - - - - - - NOTE - - -

Low p r e s s u r e c o o l a n t i n j e c t i o n (LPCI considered OPERABLE d u r i n g alignment h e a t removal w i t h r e a c t o r steam dome Residual Heat Removal (RHR) shutdown p r e s s u r e i n MODE 3, i f capable o f be and n o t o t h e r w i s e i n o p e r a b l e.

) subsystems may be and o p e r a t i o n f o r decay pressure l e s s t h a n t h e cool i ng i sol a t i on i

ng manual l y r e a l i gned MODES 2 and 3, except h i g h pressure c o o l a n t i n j e c t i o n ( H P C I )

i s n o t r e q u i r e d t o be OPERABLE w i t h r e a c t o r steam dome pressure I 150 p s i s and ADS valves a r e n o t r e q u i r e d t o be OPERABLE w i t h r e a c t o r steam dome pressure I 100 p s i g.

CONDITION A.

One low pressure ECCS i

n j e c t i o n / s p r a y subsystem i n o p e r a b l e.

OR One low p r e s s u r e c o o l a n t i n j e c t i o n (LPCI) pump i n each subsystem i n o p e r a b l e.

I REQUIRED ACTION A S Restore low pressure ECCS i n j e c t i o n / s p r a y subsystem(s) t o OPERABLE s t a t u s.

7 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months B.

Required A c t i o n and Be i n MODE 3.

associated Completion Time o f C o n d i t i o n A n o t met.

(con ti nued)

PBAPS UNIT 3 3. 5 - 1 Amendment No.

ECCS-Operating 3.5.1 ACTIONS (continued)

CON0 IT I ON C.

HPCI System inoperable.

D. HPCI System inoperable.

One low pressure ECCS injection/spray subsystem i s i noperabl e.

REQUIRED ACTION c.1 Verify by administrative means RCIC System is OPERABLE.

AND c.2 Restore HPCI System to OPERABLE status.

D. 1 Restore HPCI System to OPERABLE status.

1. 2 Restore 1 ow pressure ECCS injection/spray subsystem to OPERABLE status.

~OMPLETION TIME Immediately 14 days 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours O P E ~ B L E status.

(cont inued)

PBAPS UNIT 3 3.5-2 Amendment No.

ECCS-Operating 3.5.1 CO~DIT ION REQUI~ED ACTION One ADS valve i noperabl e.

AND One low pressure ECCS i n jection/spray subsystem inoperable.

H.

Two o r more ADS valves i noperabl e.

Restore ADS valve t o OPERABLE status.

Restore 1 ow pressure ECCS injection/spray subsystem t o OPERABLE status.

H.1 Be i n MODE 3.

AND H.2 Reduce reactor steam dome pressure t o s 100 psig.

I f.

Two o r more low pressure ECCS injection/spray subsystems i noperabl e for reasons other than Condition A.

I OR HPCI System and one o r more ADS valves inoperable.

1.1 Enter LCO 3.0.3.

I COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

mediately ondition C, D, E or F not PBAPS UNIT 3 Amendment No.

R C I C System 3.5.3 I

3.5 EMERGENCY COREl COOLING SYSTEMS {ECCS) AND REACTOR CORE ISOLATION COOLING

( R C I C ) SYSTEM 3.5.3 R C I C System t

I I

1 LCO 3.5.3 The R C I C System s h a l l be OPERABLE.

I I "

APPLICABILITY:

MODE 1, MODES 2 and 3 w i t h r e a c t o r steam dome pressure > 150 p s i g.

ACTIONS CONDITION A.

R C I C System I

I i noperabl e.

I B.

Requitred A c t i o n and associated Completion Time n o t met.

REQUIRED ACTION A. l V e r i f y by a d m i n i s t r a t i v e means High Pressure Cool ant I n j e c t i o n System i s OPERABLE.

AND A.2 Restore R C I C System t o OPERABLE s t a t u s.

8.1 Be i n MODE 3.

I COMPLETION TIME, I

Immediately 14 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months PBAPS UNIT 3 3.5-12 Amendment No.

Primary Containment 3.6.1.1 3.6 CONTAINMENT SYSTEMS 3.6.1.1 Primary Containment LCO 3.6.1.1 Primary containment shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS REQUIRED ACTION I COMPLETION TIME I

CONDITION A.

Primary containment i noperabl e.

A. 1 Restore primary containment to OPERABLE status.

I hour B.

Required Action and Be in MODE 3.

associated Completion Time not met.

I I

PBAPS UNIT 3 3.6-1 A ~ e n d ~ e n t No.

Reactor Bui lding-to-Suppression Chamber Vacuum Breakers 3.6.1.5 A C T I O ~ S (cont i nued)

CONDITION Two 1 ines with one o r more reactor building-to-suppression chamber vacuum breakers i

noperabl e f o r open i ng.

REQUIRE^ ACTION Restore a17 'vacuum breakers i n one l i n e t o ~ ~ E ~ B L E status.

Be i n MODE 3.

AND Be i n MODE 4.

COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Required Action and Associated Completion SURVEILLA~~E RE~UIREME~TS SURVE I LLANC E FREQ~ENCY SR 3.6.1.5.1 Verify Containment Atmospheric Dilution 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (CAD) System nitrogen storage tank level i s z 16 inches water column.

SR 3.6.1.5.2 Verify Safety Grade Instrument Gas (SGIG) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months System header pressure z 80 psig.

(continued)

I). Required Action and associated Completion Time of Condition C not met.

D.1 Be in MODE 3.

PBAPS UNIT 3 3.6-19 Amendment No.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.6 3.6 CONTAI~~ENT SYSTEMS 3.6.1.6 Suppression ~hamber-to~Drywe11 Vacuum Breakers LCO 3.6.1.6 APPLICABILITY:

ACTIONS Nine suppression chamber-to-drywell vacuum breakers shall be OPERABLE for opening.

Twelve suppression chamber-to-drywell vacuum breakers shall be closed, except when performing their intended function.

MODES 1, 2, and 3.

CONDITION A.

One required suppression chamber-to-drywell vacuum breaker inoperable f o r open i ng.

. One suppression chamber-to-drywel 1 vacuum breaker not cl osed.

REQU I RED ACT I ON Restore one required vacuum breaker to OPERABLE status.

Close the open vacuum breaker.

Be in MODE 3.

AND Be in MODE 4.

~

COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 10 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours PBAPS UNIT 3 3. 6-21 Amendment No.

RHR Suppression Pool Cool i ng 3.6.2.3 3.6 CONTAINME~T SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cool ing LCO 3.6.2.3 Two RHR suppression pool cool i ng Subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION A.

One RHR suppression pool cool i ng subsystem i noperabl e.

Two RHR suppression pool cooling subsystems i noperabl e.

Required Action and REQUIRED ACTION COMPLETION TIME A. 1 Restore RHR 7 days suppression pool cooling subsystem to OPERABLE status.

Restore one RHR 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months suppression pool cooling subsystem to OPERABLE status.

Be in MODE 3.

Be i n MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months PBAPS UNIT 3 3.6-27 A~endment No.

RHR Suppression Pool Spray 3.6.2.4 REQUIRED ACTION i

C O ~ P L E T I O ~

TIME 3.6 ~ O N ~ A ~ N ~ ~ ~ T SYSTEMS 3.6.2. 4 Res iduaf Heat Removal (RHR) Suppression Pool Spray LCO 3.6.2.4 Two RHR suppression pool spray subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, ACTIONS CONDITION A.

One RHR suppression pool spray subsystem i

noperabl e.

B, Two RHR suppression pool spray subsystems i

noperabl e.

C.

Required Action and associated Completion Time not met.

A. 1 Restore RNR suppression pool spray subsystem t o OPERABLE status.

7 days B.1 Restore one RHR suppression pool spray subsystem t o OPERABLE status, 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months c.1 Be i n MODE 3.

I 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months PBAPS UNIT 3 3.6-29 Amendment No.

Secondary Containment 3.6.4.1 3.6 CONTAI~ME~T SYSTEMS 3.6,4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

G APPLICABILIJY:

MODES 1, 2, and 3, During movement o f irradiated fuel assemblies i n the During CORE ALTE~TIONS, During operations with a potential f o r draining the reactor secondary containment, vessel (OPDRVs).

ACTIONS CON0 I T I ON A.

Secondary containment inoperable i n MODE 1, 2, or 3.

B.

Required Action and as soc i a t ed Compl e t i on Time o f Condition A not met.

C.

Secondary c~ntainment inoperable during movemeflt o f irradiated fuel assemblies i n the secondary contain~ent, during CORE ALTE~JIO~S, o r during OPDRVs.

REQUI~ED ACTION CO~PLETION TlME A. 1 Restore secondary Containment t o OPERABLE status.

6.1 Be i n NODE 3.

Suspend movement o f irradiated fuel.

assemblies i n the secondary containment.

I hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately (continued)

PBAPS UNIT 3 3.6-34 A~endment No.

SGT System 3.6.4.3 3.6 CONTAINMENT SYSTEMS 3.6.4.3 Standby Gas Treatment (SGT) System LCO 3.6.4.3 Two SGT subsystems s h a l l be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, D u r i n g ~ o v e m e n t o f i r r a d i a t e d f u e l assemblies i n t h e D u r i n g CORE ALTERATIONS,

D u r i n g o p e r a t i o n s w i t h a p o t e n t i a l f o r d r a i n i n g t h e r e a c t o r secondary containment, v e s s e l (OPDRVs).

ACTIONS CONDITION A.

One SGT subsystem i noperabl e.

B.

Required A c t i o n and a s s o c i a t e d Completion Time o f C o n d i t i o n A not met i n MODE 1, 2, o r 3.

C.

Required A c t i o n and associ a t e d Compf e t i on T i n e o f C o n d i t i o n A n o t met d u r i n g movement o f i r r a d i a t e d f u e l assemblies i n t h e secondary containment, d u r i n g CORE A ~ T E R A T I O ~ S,

o r d u r i n g OPDRVs.

REQUIRED ACTION A. l Restore SGT subsystem t o OPERABLE s t a t u s.

B. l Be i n MODE 3.

c.1 Place OPERABLE SGT subsystem i n opera t i on.

~~

CO~PLETION TIME 7 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately

( c o n t i nued 1 PBAPS U N I T 3 3.6-40 Amendment No.

SGT System 3.6.4.3 1 COMPLETIO~ TIME ACTIONS COMDIT ION C.

(cont i nued)

D.

Two SGT subsystems inoperable in MODE 1, 2, or 3.

E.

Two SGT subsystems inoperable during move~ent o f irradiatec fuel assemblies in the secondary containment, during CORE A ~ T E ~ T I O ~ S,

or during OPDRVs.

PBAPS UNIT 3 R E Q ~ I ~ E D ACTION Suspend movement o f irradiated fuel assembl ies in secondary containment.

Suspend CORE ALTERATIONS AND Initiate action to suspend OPDRVs.

1. 1 Suspend movement o f irradiated fuel assembl ies i n secondary containment.

2 Suspend CORE A L T E ~ T I O ~ S.

.3 Initiate action to suspend OPDRVs.

Immediately.

Immediately hned i at el y mediately

~ediately 3.6-41 Amend~ent No.

HPSW System 3.7.1 3.7 PLANT SYSTEMS 3.7.1 High Pressure Service Water (HPSW) System LCO 3.7.1 Two HPSW subsystems shall be OPERABLE.

APPLICABXLIT~:

MODES 1, 2, and 3.

ACTIONS CONDITION A,

One HPSW subsystem i

noperabl e, Both HPSW subsystems i

noperabl c

e.

- - ~ _ _ _

REQUIRED ACTION

NOTE-------------

Enter appl icabl e Conditions and Required Actions o f LCO 3.4.7, "Residual Heat Removal (RHR) Shutdown Cool ing System-Hot Shutdown," for RWR shutdown cool ing made inoperable by HPSW System.

-. -. - - - - - - - ~. - e - - L - - - - - - - - - -

A. 1 Restore HPSW subsystem' t o OPERABLE status.

*-- NOTE-------------

Enter applicable Conditions and Required Actions o f LCO 3.4.7 f o r RHR shutdown coo7 ing made inoperable by YPSW System.

--~---.---~--------------

Restore one HPSW subsystem t o OPERABLE status.

7 days 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months PBAPS UNIT 3

HPSW System 3 J. 1 SURVEILLAN~E SR 3,7.1.1 Verify each HPSW manual and power operated valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.

Required Action and associated Completion Be in MODE 3.

FREQUENCY 31 days PBAPS UNIT 3 3.7-2

~ e n d m e n t No,

MCREV System 3.7.4 I C O ~ P L E T I O ~

TIME 3.7 PLANT SYSTEMS 3.7.4 Main Control Room Emergency Ventilation (MCREV) System LCO 3.7.4 Two MCREV subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3, During ~ v e m e n t of irradiated fuel assemblies in the During CORE ALTE~TIONS, During operations with a potential for draining the reactor secondary containment,

vessel (OPDRVs).

ACTIONS CO~DITION A.

One MCREV subsystem i noperabl e.

B.

Required Action and associated Completion Time o f Condition A not met in MODE 1, 2, or 3.

C.

Required Action and associated Completion Time o f Condition A not met during movement of irradiated fuel assemblies in the secondary containment, during CORE ALTE~TIONS, or during OPDRVs.

REQUIRED ACTION A. 1 Restore MCREV subsystem to OPERABLE status.

B. l Be in MODE 3.

OR 7 days 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately (continued)

PBAPS UNIT 3 3. 7-7 Amendment No.,

ACT IONS MCREV System 3.7.4

~ O N D I T I O ~

C.

(continued)

D.

Two MCREV subsystems inoperable in NODE 1, 2, or 3.

E.

Two MCREV subsystems i noperabl e during movement o f irradiated fuel assemblies in the secondary containment, during CORE A L T E ~ T I ~ ~ N S,

or during OPDRVs.

REQU I RED ACT I ON C.2.1 Suspend movement o f i rradi ated fuel assembl ies in the secondary containment.

C.2.2 Suspend CORE ALTE~TIONS.

AND C.2.3 Initiate action to suspend OPDRVs.

1. 1 1

Suspend movement o f irradiated fuel assembl ies in the secondary containment.

E.2 Suspend CORE ALTERATIONS, E.3 Initiate action to suspend OPDRVs.

CO~PLETION TIME Immediately Immediately Immediately

~ediately mediately nmedi ately PBAPS UNIT 3 3.7-8 Amendment No,

Main Condenser Offgas 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Mai n Condenser O f fgas LCO 3.7.5 The gross gamma activity rate of the noble gases measured a t the steam jet a i r ejector (SJAE) discharge a t the offgas sample rack shall be 12; 320,000 /rCi/second after decay o f 30 minutes.

APPLICABIlITY:

MODE 1, MODES 2 and 3 w i t h any main steam line not isolated and SJAE i n operation.

ACTIONS CONDITION A.

Gross gamma activity rate o f the noble gases not w i t h i n limit.

B.

Required Action and associated Completion Time not met, REQU I RED ACT ION A. 1 Restore gross gamma activity rate o f the noble gases t o w i t h i n limit.

B.1 Isolate a l l main 1111)

OR 8.2 Isolate SJAE.

OR B.3 Be i n MODE 3.

steam lines.

COMPLETIO~ TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 12 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours PBAPS UNIT 3 3. 7-30 A ~ ~ n d ~ e n t No.

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION E.

One offsite circuit i noperabl e.

AND One DG inoperable.

F.

Two or more DGs inoperable.

G.

Required Action and associated Completion Time of Condition A, C, D, E, or F not met.

OR Requi red Act i on B. 2, B.3, B.4.1, B.4.2, or B.5 and associated Completion Time not met.

I REQUIRE^ ACTION NOTE---..--------

Enter applicable Conditions and Required Actions o f LCO 3.8. 7, "Di stri but i on Systems-Operating, " when Condition E is entered with no AC power source to any 4 kV emergency bus.

E. 1 Restore offsite circuit to OPERABLE status.

E.2 Restore DG to OPERABLE status.

F.1 Restore a71 but one DG to OPERABLE status.

G O 1 Be in MODE 3.

PBAPS UNIT 3 3.8-5 CO~PLETIO~

TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 12 hours (cont i nued)

Amendment No.

DC Sources-Operating 3.8.4 ACTIONS (continuedl CONDITION B. One Unit 2 DC electrical power subsystem inoperable for reasons other than Condition A.

C.

One Unit 3 DC el ectri cal power subsystem inoperable.

REQUIRED ACTION

-.*---------- NOTE------------

Enter applicable Conditions and Required Actions o f LCO 3.8.7, "Distribution Systems-Operating," when Condition B results in de-energization o f a Unit 3 4 kV emergency bus, B. 1 Restore Unit 2 DC electrical power subsystem to OPERABLE status.

c.1 Restore Unit 3 DC el ectri cal power subsystem to OPERABLE status.

D.

Required Action and Associated Completion Time of Condition A, B, or C not met, I

D. 1 Be in MODE 3.

E.

Two or more inoperable DC electrical power subsystems.

E.1 Enter LCO 3.0.3.

COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 2 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately PBAPS UNIT 3 3.8-29 Amendment No.

Distribution Systems-Operating 3.8.7 SURVEIL~A~CE ACTIONS (continued)

CONDITION FREQUENCY D.

One Unit 3 DC e l e c t r i c a l power d i s t r i b u t i o n subsystem i

noperabl e, E.

Required Action and associ a t ed Compl e t i on Time o f Condition A, 6, C, or 0 not met, F.

Two o r more inoperable e l e c t r i c a l power d i s tr i but i on subsystems that result i n a loss o f function.

REQUIRED ACTION D. 1 Restore Unit 3 DC e l ectricaf power di s t r i but i on subsystem t o OPERABLE

status, E. 1 Be i n MODE 3.

I Enter LCO 3.0.3.

CO~PLETION TIME 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of f a i l u r e t o meet LCO 3.8.7.a 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

[mediately I

SR 3.8.7.1 Verify:

a, Correct breaker a1 ignments t o required AC e l e c t r i c a l power distribution subsystems; and Indicated power avai 1 abi 1 i ty t o required AC and DC electrical power d i s t r i b u t i o n subsystems.

b.

1 7 days I

PBAPS UNIT 3 I

3.

8-43 Amend~ent No.

ENCLOSURE 3 TECHNICAL SPECIFICATION BASES PAGE INSERTS PROPOSER CHANGES TO TECHNICAL SPECIFICATION 6ASES PAGES UNIT 2 B 3.3-203 B 3.3-205 B 3.4-18 B 3.5-7 B 3.5-8 B 3.5-9 B 3.5-17 B 3.5-26 B 3.5-27 B 3.5-30 B 3.6-3 B 3.6-5 B 3.6-38 B 3.6-39 B 3.6-41 B 3.6-45 6 3.6-46 B 3.6-47 B 3.6-58 B 3.6-59 B 3.6-62 B 3.6-63 B 3.6-75 B 3.6-77 B 3.6-87 B 3.6-88 B 3.6-89 B 3.6-90 B 3.7-4 B 3.7-5 B 3.7-10 6 3.7-18 B 3.7-19 6 3.7-21 B 3.7-23 B 3.7-24 B 3.8-17 B 3.8-39 B 3.8-64 B 3.8-71 B 3.8-91 B 3.8-92 UNIT 3 B 3.3-203 B 3.3-205 B 3.4-18 6 3.5-7 B 3.5-8 B 3.5-9 B 3.5-17 6 3.5-26 B 3.5-27 B 3.5-30 B 3.6-3 B 3.6-5 B 3.6-38 6 3.6-39 B 3.6-41 6 3.6-45 B 3.6-46 6 3.6-47 B 3.6-58 B 3.6-59 B 3.6-62 B 3.6-63 B 3.6-75 B 3.6-77 6 3.6-87 6 3.6-88 6 3.6-89 6 3.6-90 B 3.7-4 B 3.7-5 B 3.7-10 B 3.17-18 B 3.7-19 B 3.7-21 6 3.7-23 B 3.7-24 6 3.8-17 B 3.8-39 B 3.8-64 B 3.8-71 B 3.8-91 B 3.8-92

Peach Bottom Atomic Power Station TSTF-423 LAR Technical Specification Bases Page Inserts Page 1 LCO 3.3.8.2 RPS Electric Power Monitoring INSERT 1 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

INSERT 2

3.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

LCO 3.4.3 Safety / Relief Valves INSERT 1

3.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

LCO 3.5.1 ECCS - Operating INSERT 1 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 12) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

INSERT 2 H.1 and H.2 If two or more ADS valves are inoperable, there is a reduction in the depressurization capability.

The plant must be brought to a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reactor steam dome pressure reduced to 100 psig within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

INSERT 3

12.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

LCO 3.5.3, RCIC System INSERT 1 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 4) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Peach Bottom Atomic Power Station TSTF-423 LAR Technical Specification Bases Page Inserts Page 2 INSERT 2

4.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

LCO 3.6.1.1, Primary Containment INSERT 1 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 8), because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

INSERT 2

8.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

LCO 3.6.1.5 Reactor Building-to-Suppression Chamber Vacuum Breakers INSERT 1 D.1 If one line has one or more vacuum breakers inoperable for opening and they are not restored within the Completion Time in Condition C, the remaining vacuum breakers in the remaining line can provide the opening function. The plant must be brought to a condition in which the overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 1) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state. The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

INSERT 2

1.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

Peach Bottom Atomic Power Station TSTF-423 LAR Technical Specification Bases Page Inserts Page 3 LCO 3.6.1.6 Suppression Chamber-to-Drywell Vacuum Breakers INSERT 1 B.1 If a required suppression chamber-to-drywell vacuum breaker is inoperable for opening and is not restored to OPERABLE status within the required Completion Time, the plant must be brought to a condition in which the overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state. The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

INSERT 2

3.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

LCO 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling INSERT 1 B.1 If one RHR suppression pool cooling subsystem is inoperable and is not restored to OPERABLE status within the required Completion Time, the plant must be brought to a condition in which the overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref.

2) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state. The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

INSERT 2

2.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

LCO 3.6.2.4 Residual Heat Removal (RHR) Suppression Pool Spray INSERT 1 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 2) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

Peach Bottom Atomic Power Station TSTF-423 LAR Technical Specification Bases Page Inserts Page 4 INSERT 2

2.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

LCO 3.6.4.1 Secondary Containment INSERT 1 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3), because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

INSERT 2

3.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

LCO 3.6.4.3 Standby Gas Treatment (SGT) System INSERT 1 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

INSERT 2 Therefore, the plant must be brought to a MODE in which the overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state. The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

INSERT 3

3. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

Peach Bottom Atomic Power Station TSTF-423 LAR Technical Specification Bases Page Inserts Page 5 LCO 3.7.1 High Pressure Service Water (HPSW) System INSERT 1 B.1 If one HPSW subsystem is inoperable and not restored within the provided Completion Time, the plant must be brought to a condition in which the overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 5) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state. The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

INSERT 2

5. NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

LCO 3.7.4 Main Control Room Emergency Ventilation (MCREV) System INSERT 1 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 5) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

INSERT 2 Therefore, the plant must be brought to a MODE in which the overall plant risk is minimized. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 5) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short. However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state. The allowed Completion Time is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

INSERT 3

5.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

Peach Bottom Atomic Power Station TSTF-423 LAR Technical Specification Bases Page Inserts Page 6 LCO 3.7.5 Main Condenser Offgas INSERT 1 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

INSERT 2

3.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

LCO 3.8.1 AC Sources - Operating INSERT 1 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 11) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

INSERT 2

11.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

LCO 3.8.4 DC Sources - Operating INSERT 1 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 6) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

INSERT 2

6.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

LCO 3.8.7 Distribution Systems - Operating INSERT 1 Remaining in the Applicability of the LCO is acceptable because the plant risk in MODE 3 is similar to or lower than the risk in MODE 4 (Ref. 3) and because the time spent in MODE 3 to perform the necessary repairs to restore the system to OPERABLE status will be short.

However, voluntary entry into MODE 4 may be made as it is also an acceptable low-risk state.

INSERT 2

3.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

RPS Electric Power Monitoring B 3.3.8,2 BASES ACTIONS (continued)

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is sufficient for the plant operations personnel to take corrective actions and is acceptable because it minimizes risk while allowing time for restoration or removal from service o f the electric power monitoring assembl ies.

Alternately, if it is not desired to remove the power supply(s) from service (e.g,, as in the case where removing the power supply(s) from service would result in a scram or isolation), Condition C or 0, as applicable, must be entered and its Required Actions taken.

If any Required Action and associated Completion Time of Condition A or B are not met in MODE 3, 4, or 5 with any control rod withdrawn from a core cell containing one or more fuel assemblies, the operator must i~ediately initiate action to fully insert a71 insertable control rods in core cells containing one or more fuel assemblies.

Action 0.1 results in the least reactive condition for the reactor core and ensures that the safety function of the RPS (e.g., scram o f control rods) is not required.

Required PBAPS UNIT 2 B 3.3-203

( con t i nued )

Revision No,

RPS Electric Power Monitoring B 3.3.8.2 BASES SR 3.3.8.2.4 (continued) per power monitoring assembly is required to be tested.

This Surveillance overlaps with the ~ ~ N N E L C A L I B ~ T I ~

to provide complete testing of the safety function. The system functional test o f the Class 1E circuit breakers is included as part o f this test to provide complete testing of the safety function.

operating, the associated electric power monitoring assembly woul d be i noperabl e.

If the breakers are incapable of The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

Operating experience has shown that these components will pass the Surveillance when performed at the 24 month Frequency REFERENCES

1.

UFSAR, Section 7.2.3.2.

2.

NRC Generic Letter 91-09, "Modification o f Surveillance Interval for the Electrical Protective Assemblies in Power Supplies for the Reactor Protection System.'

PBAPS UNIT 2 B 3.3-205 Revision No.

SRVs and SVs B 3.4.3 BASES SURVEILLANCE RE~UIRE~E~TS SR 3.4.3.2 (continued)

The pneumatic actuator o f each SRV valve i s stroked t o v e r i f y that the second stage p i l o t disc rod i s mechanically displaced when the actuator strokes.

movement i s d e t e r ~ i n e d by the measurement o f actuator rod travel.

The t o t a l amount o f ~ovement o f the second stage p i l o t rod from the valve closed p o s i t i o n t o the open position shall meet c r i t e r i a established by the SRV supplier.

I f the valve f a i l s t o actuate due only t o the f a i l u r e o f the solenoid, but i s capable o f opening on overpressure, the safety function o f the SRV i s considered OPE~BLE Second stage p i l o t rod Operating experience has shown that these com~onents w i l l pass the SR when performed a t the 24 month Frequency, which i s based on the r e f u e l i n g outage.

Therefore, the Frequency was concluded t o be acceptable from a r e l i a b i l i t y standpoint.

REFERENCES

1.

NEDC-32183P, "Power Rerate Safety Analysis Report f o r Peach Bottom 2 & 3," May 1993,

~ ~ A P S UNIT 2 B 3.4-18 Revision No.

ECCS-Operating B 3.5.1 BASES ACTIONS (continued)

If the inoperable low pressure ECCS subsystem cann must be brought to a MODE in which RABLE status within the associated To achieve this status, t st MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months The allowed Completion T on operat i ng experi ence, to nditions from full power cond d without challenging plant systems.

C - 1 and C.2 If the HPCI System is inoperable and the RCIC System is i~ediately verified to be OPERABLE, the HPCI System must be restored to OPERABLE status within 14 days.

Condition, adequate core cool ing is ensured by the OPE~BILITY o f the redundant and diverse low pressure ECCS injection/spray subsystems in conjunction with ADS, Also, the RCIC System will automatically provide makeup water at most reactor operat i ng pressures. Imedi ate veri f i cat i on of RCIC OPERABILITY is therefore required when HPCI is inoperable. This may be performed as an administrative check by e~amining logs or other info~ation to determine if o f service for maintenance or other reasons, It If the In this rform the Surveillances needed to RABILITY of the RCIC System.

OPE~BILITY o f the RCIC System cannot be verified i~ediately, however, Condition E must be inmediately entered. If a single active component fails concurrent with a design basis LOCA, there is a potential, depending on the specific failure, that the minimum required ECCS equip~ent will not be available. A 14 day Completion Time is based on a reliability study cited in Reference 9 and has been found to be acceptable through operating experience.

D.1 and D.2 If any one 1 ow pressure ECCS inject ion/spray subsystem i s inoperable in addition to an inoperable HPCI System, the inoperable low pressure ECCS inj~~tion/spray subsystem or the HPCI System must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this Condition, adequate core cooling is kont i nued 1 PBAPS UNIT 2 B 3.5-7 Revision No,

ECCS-Operating B 3.5.1 BASES ACT IONS D. l and 0.2 (continued) ensured by the OPE~6ILITY o f the ADS and the remaining low pressure ECCS subsystems, However, the overall ECCS re1 iabil ity is significantly reduced because a single failure in one o f the remaining O P E ~ B L E subsystems concurrent with a design basis LOCA may result in the ECCS not being able to perform its intended safety function.

Since both a high pressure system (HPCI) and a low pressure subsystem are inoperable, a more restrictive Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is required to restore either the WPCI System or the low pressure ECCS injection/spray subsystem to OPERABLE status. This Completion Time i s based on a reliability study cited in Reference 9 and has been found to be acceptable through operating experience.

I The LCO requires five ADS valves to be OPERABLE in order to provide.the ADS function. Reference 7 contains the results of an analysis that evaluated the effect of one ADS valve being out o f service. Per this analysis, operation o f only four ADS valves will provide the required depressurization, However, overall re1 i abi 1 i ty o f the ADS i s reduced, because a single failure in the OPERABLE ADS valves could result in a reduction in depressurization capability. Therefore, operation is only allowed for a limited time. The 14 day Co~pletion Time is based on a reliability study cited in Reference 9 and has been found to be acceptable through operating experience.

l cant i nued 1 PBAPS UNIT 2 B 3.5-8 Revision No.

BASES ECCS-Operating B 3.5.1 ACT I ONS (c~ntinued)

I f any one low pressure ECCS inj~ction/spray subsystem is inoperable in addition to one inoperable ADS valve, adequate core cooling is ensured by the OPE~~ILITY o f HPCI and the remaining low pressure ECCS injection/spray subsystem.

However, overall ECCS reliability is reduced because a single active component failure concurrent with a design basis LOCA could result in the minimum required ECCS equipment not being available. Since both a high pressure system (ADS) and a low pressure subsystem are inoperable, a more restrictive Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months i s required to restore either the low pressure ECCS subsystem or the ADS valve to OPERABLE status. This ~o~pletion Time i s based on a reliability study cited in Reference 9 and has been found to be acceptable through operating experience.

n ust be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months conditions-from full power conditions in an orderly minner and without challenging plant systems.

When mu1 tiple ECCS subsystems are inoperable (for reasons other than the second Condition o f Condition A), as stated in Condition I, the plant is in a condition outside o f the accident analyses. Therefore, LCO 3.0.3 must be entered i mmedi at el y.

SURVEILLA~CE SR 3.5.1.1

~ E Q U I R E ~ E ~ T S The flow path piping has the potential to develop voids and pockets o f entrained air. Maintaining the pump discharge lines o f the HPCI System, CS System, and LPCI subsystems full of water ensures that the ECCS will perform properly, (cont i nued 1 PBAPS UNIT 2 B 3.5-9 Revision No.

ECCS -Opera t i ng B 3.5.1 BASES

( c o n t i n u e d )

REFERENCES

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

1 1 L A.

UFSAR, S e c t i o n 6.4.3.

UFSAR, S e c t i o n 6.4.4.

UFSAR, S e c t i o n 6.4.1.

UFSAR, Sections 4.4.5 and 6.4.2.

UFSAR, S e c t i o n 14.6.

10 CFR 50, Appendix K.

NEDC-32163P, "Peach Bottom Atomic Power S t a t i o n U n i t s 2 and 3 SAFER/GESTR-LOCA Loss o f Coolant A c c i d e n t A n a l y s i s, January 1993.

10 CFR 50.46.

Memorandum f r o m R.L.

Baer ( N R C ) t o V. S t e l l o, Jr.

( N R C ),

"Recommended I n t e r i m Revisions t o LCOs f o r ECCS Components, December 1, 1975.

UFSAR, S e c t i o n 10.17.6.

Issue Report 189167, O p e r a b i l i t y o f RHR w h i l e i n Test Modes/Torus Cooling.

PBAPS UNIT 2 B 3.5-17 R e v i s i o n No.

R C I C System B 3.5.3 BASES

( c o n t i n u e d )

ACT IONS A Note p r o h i b i t s t h e a p p l i c a t i o n o f LCO 3.0.4.b t o an i n o p e r a b l e R C I C system.

There i s an i n c r e a s e d r i s k a s s o c i a t e d w i t h e n t e r i n g a MODE or o t h e r s p e c i f i e d c o n d i t i o n i n t h e A p p l i c a b i l i t y w i t h an i n o p e r a b l e R C I C system and t h e p r o v i s i o n s o f LCO 3.0.4.b, which a l l o w e n t r y i n t o a MODE or o t h e r s p e c i f i e d c o n d i t i o n i n t h e A p p l i c a b i l i t y w i t h t h e LCO n o t met a f t e r performance o f a r i s k assessment addressing i n o p e r a b l e systems and components, should n o t be a p p l i e d i n t h i s c i rcumstance.

A. 1 and A.2 I f t h e R C I C System i s i n o p e r a b l e d u r i n g MODE 1, o r MODE 2 o r 3 w i t h r e a c t o r steam dome pressure > 150 p s i g, and t h e H P C I System i s immediately v e r i f i e d t o be OPERABLE, t h e R C I C System must be r e s t o r e d t o OPERABLE s t a t u s w i t h i n 14 days.

I n t h i s C o n d i t i o n, loss o f t h e R C I C System w i l l n o t a f f e c t t h e o v e r a l l p l a n t c a p a b i l i t y t o p r o v i d e makeup i n v e n t o r y a t h i g h r e a c t o r p r e s s u r e s i n c e t h e H P C I System i s t h e o n l y h i g h pressure system assumed t o f u n c t i o n d u r i n g a loss o f c o o l a n t a c c i d e n t (LOCAL OPERABILITY o f H P C I i s t h e r e f o r e immediately v e r i f i e d when t h e R C I C System i s i n o p e r a b l e.

T h i s may be performed as an a d m i n i s t r a t i v e check, by examining l o g s o r o t h e r i n f o r m a t i o n, t o determine i f H P C I i s o u t o f s e r v i c e f o r maintenance o r o t h e r reasons.

It does n o t mean i t i s necessary t o p e r f o r m t h e S u r v e i l l a n c e s needed t o demonstrate t h e OPERABILITY o f t h e H P C I System.

I f t h e ILITY o f t h e H P C I System cannot be v e r i f i e d a t e l y, however, C o n d i t i o n B must be immediately entered.

For c e r t a i n t r a n s i e n t s and abnormal events w i t h no LOCA, R C I C (as opposed t o H P C I ) i s t h e p r e f e r r e d source o f makeup c o o l a n t because o f i t s r e l a t i v e l y small c a p a c i t y,

which a l l o w s e a s i e r c o n t r o l o f t h e RPV water l e v e l.

Therefore, a l i m i t e d t i m e i s allowed t o r e s t o r e t h e i n o p e r a b l e R C I C t o OPERABLE s t a t u s.

The 14 day Completion Time i s based on a r e l i a b i l i t y study (Ref. 3) t h a t e v a l u a t e d t h e impact on ECCS a v a i l a b i l i t y,

assuming v a r i o u s components and subsystems were taken o u t o f s e r v i c e.

The r e s u l t s were used t o c a l c u l a t e t h e average a v a i l a b i l i t y o f ECCS equipment needed t o m i t i g a t e t h e consequences o f a LOCA as a f u n c t i o n o f allowed outage times (AOTs).

Because o f s i m i l a r f u n c t i o n s o f H P C I and R C I C, t h e AOTs W e., Completion Times) determined f o r HPCI a r e a l s o a p p l i e d t o R C I C.

OPERABLE s t a t u s r i f t h e H P C I System t be brought t o a R e v i s i o n N o -

PBAPS UNIT 2 B 3.5-26

R C I C System B 3.5.3 BASES ACT ION S

( c o n t i nued 1 easonable, based on o p e r a t i n g experience, t o reach t h e r e q u i r e d p l a n t c o n d i t i o n s from f u l l power c o n d i t i o n s i n an o r d e r l y manner and w i t h o u t c h a l l enging p l a n t systems.

SURVEILLANCE SR 3.5.3.1.

REQUIREMENTS The f l o w p a t h p i p i n g has t h e p o t e n t i a l t o develop v o i d s and pockets o f e n t r a i n e d a i r,

M a i n t a i n i n g t h e pump d i s c h a r g e l i n e o f t h e R C I C System f u l l o f water ensures t h a t t h e system w i l l p e r f o r m p r o p e r l y, i n j e c t i n g i t s f u l l c a p a c i t y i n t o t h e Reactor Coolant System upon demand.

T h i s w i l l a l s o p r e v e n t a water hammer f o l l o w i n g an i n i t i a t i o n s i g n a l.

An acceptable method o f e n s u r i n g t h e l i n e i s f u l l i s t o vent a t t h e h i g h p o i n t s.

The 3 1 day Frequency i s based on t h e gradual n a t u r e o f v o i d b u i l d u p i n t h e R C I C p i p i n g, t h e procedural c o n t r o l s governing system o p e r a t i o n, and o p e r a t i n g experience.

SR 3.5.3.7 V e r i f y i n g t h e c o r r e c t alignment f o r manual, power operated, and automatic v a l v e s i n t h e R C I C f l o w p a t h p r o v i d e s assurance t h a t t h e proper f l o w p a t h w i l l e x i s t f o r R C I C o p e r a t i o n.

T h i s SR does n o t apply t o valves t h a t a r e locked, sealed, o r o t h e r w i s e secured i n p o s i t i o n s i n c e t h e s e valves were v e r i f i e d t o be i n t h e c o r r e c t p o s i t i o n p r i o r t o l o c k i n g, s e a l i n g, o r securing.

A v a l v e t h a t r e c e i v e s an i n i t i a t i o n s i g n a l i s a l l o w e d t o be i n a nonaccident p o s i t i o n p r o v i d e d t h e v a l v e w i l l a u t o m a t i c a l l y r e p o s i t i o n i n t h e proper s t r o k e time.

T h i s SR does n o t r e q u i r e any t e s t i n g o r v a l v e m a n i p u l a t i o n ; r a t h e r, i t i n v o l v e s v e r i f i c a t i o n t h a t those valves capable o f p o t e n t i a l l y b e i n g m i s p o s i t i o n e d a r e i n t h e c o r r e c t p o s i t i o n.

t h a t cannot be i n a d v e r t e n t l y misaligned, such as check valves.

For t h e R C I C System, t h i s SR a l s o i n c l u d e s t h e steam f l o w p a t h f o r t h e t u r b i n e and t h e f l o w c o n t r o l l e r p o s i t i o n.

T h i s SR does n o t apply t o v a l v e s

( c o n t i n u e d )

PBAPS UNIT 2 B 3.5-27 R e v i s i o n No.

RCIC System B 3.5.3 BASES (cont i nued)

REFERENCES

1.

UFSAR, Section 1.5,

2.

UFSAR, Section 4.7.

3.

Memorandum from R.L.

Baer (NRC) to V. Stello, Jr.

(WRC),

~ R e ~ o ~ e n d e d Interim Revisions to LCOs f o r ECCS Com~onents, " December 1, 1975.

PBAPS UNIT 2 8 3.5-30 Revision No.

Primary Containment 6 3.6.1.1 BASES LCO Individual leakage rates specified for the primary containment air lock are addressed in LCO 3.6.1.2.

(continued)

APPL ICAB I L ITY In MODES 1, 2, and 3, a DBA could cause a release o f radioactive material to primary containment.

and 5, the probability and consequences o f these events are reduced due to the pressure and temperature limitations o f these MODES.

Therefore, primary containment is not required to be OPERABLE in MOOES 4 and 5 to prevent leakage o f radioactive material from primary containment.

In MOOES 4 ACTIONS A.1 In the event primary containment is inoperable, primary containment must be restored' to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

time to correct the problem commensurate with the importance o f maintaining primary containment O P E ~ B I L I T Y during MODES I, 2, and 3.

This time period also ensures that the probability o f an accident (requiring primary containment OPERABILITY) occurring during periods where primary containment is inoperable is minim The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provides a period o f If primary containment cannot within the required Completio brought to a MODE i n which th power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.1.1.1 REQU I RENf NTS Maintaining the primary containment OPERABLE requires compliance with the visual examinations and leakage rate test requi~ements o f the Primary ~o~tainment Leakage Rate Testing Program.

(SR 3.6.1.2.1),

or main steam isolation Failure to meet air lock leakage testing PBAPS UNIT 2 8 3.6-3 Revision No.

Primary Containment B 3.6.1.1 BASES (continued) 1 REFERENCES

1.

2.

3.

4.

5.

6.

7.

UFSAR, Section 14.9.

Letter G94-PEPR-183, Peach Bottom Improved Technical Specification Project Increased Drywell and Suppression Chamber Pressure Analytical Limits, from G.V. Kumar (GE) to A.A. Winter (PECO), August 23, 1994.

10 CFR 50, Appendix J, Option 6.

Safety Evaluation by the Office o f Nuclear Reactor Regulation Supporting Ame~dment Nos. 127 and 130 to Facility Operating license Nos. DPR-44 and DPR-56, dated February 18, 1988.

NEI 94-01, Revision 0, "Industry Guideline for Implementing Performance-Based Option o f 10 CFR Part 50, Appendix J."

ANSI/ANS-56.8-1994, "Contai nment Sys tern Leakage Test i ng Requ i remen t s.

I' Peach Bottom Atomic Power Station Evaluation for Extended Final Feedwater Reduction, NEDC-32707PY Supplement 1, Revision 0, May, 1998.

PBAPS UNIT 2 B 3.6-5 Revision No.

Reactor Bui lding-to-Suppression Chamber Vacuum Breakers B 3.6.1.5 BASES "Suppression Chamber-to-Drywell Vacuum Breakers. " The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the redundant capability afforded by the remaining breakers, the fact that the OPERABLE breaker in each of the lines is closed, and the low probabil i ty o f an event occurring that would require the vacuum breakers to be OPERABLE during this period.

With one or more lines with two vacuum breakers not' closed, primary containment integrity is not maintained. Therefore, one open vacuum breaker must be closed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , This Completion Time is consistent with the ACTIONS o f LCO 3.6, 1.1, "Primary Co~tainment," which requires that primary containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

With one line with one or more vacuum breakers inoperable for opening, the leak tight primary containment boundary i s intact. The abili to mitigate an e nt that causes a con t ai nment depres izatjon lis threa ned if one or more vacuum breakers in at least one vacuum breaker penetration are not OPERABLE.

Therefore, the inoperable vacuum breaker must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This is consistent with the Co~letion Time for Condition A and the fact that the leak tight primary containment boundary is bei ng mai ntat ned.,

With two lines with one or more vacuum breakers inoperable for opening, the primary containment boundary is intact.

However, in the event o f a containment depressurization, the function o f the vacuum breakers is lost.

Therefore, all vacuum breakers in one line must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This Completion Time is consistent with the ACTIONS o f LCO 3.6.1-1, which requires that primary containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Icontinued)

PBAPS UNIT 2 B 3.6-38 Revision No,

Reactor ~uilding-to-Suppression Chamber Vacuum Breakers 6 3.6.1.5 BASES If any Required Action and associated Completion Time be met, the plant must be brought t o a MODE i n which the LCO does not apply.

brought t o a t least MODE 3 within I2 hours and t o MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed*~o~pletion Times are reasonabl e, based on operating experience, t o reach the required plant conditions from f u l l power conditions i n an orderly manner and without chal 1 enging plant systems.

To achieve this status, the plant must be SURVEILLA~CE SR 3.6.1.5.1 RE~UIRE~ENTS Verifying that the level i n the CAD l i q u i d nitrogen tank i s 2 16 inches water column w i l l ensure a t least 7 days o f post-LOCA SGIG System operation.

This minimum volume o f l i q u i d nitrogen allows sufficient time a f t e r an accident t o replenish the nitrogen supply i n order t o maintain the design function of the reactor building-to-suppression vacuum breakers.

The level i s verified every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months t o ensure that the system i s capable o f performing i t s intended isolation function when required.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency i s based on operating experience, which has shown t o be an e period t o verify l i q u i d n i t en supply.

The 24 uency also signifies the impo r maintaining the design func bui lding-to-suppression chamber vacuum breakers.

rice of the SGIG of the reactor SR 3.6.1.5.2 This SR ensures that the pressure i n the SGIG System header' i s L 80 psig.

This ensures that the post-LOCA nitrogen pressure provided t o the valve operators and valve seals that i s adequate f o r the SGIG t o perform i t s design funct i on. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency was devel oped cons i deri ng the importance o f the SG16 System f o r maintaining the design function o f the reactor bui~ding=toosuppression chamber vacuum breakers.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency i s also considered t o be adequate t o ensure timely detection o f any breach i n the SGIG System which would render the system incapable o f performing i t s function.

l cont i nued 1 PBAPS UNIT 2 B 3.6-39 Revision No.

Reactor Building-to-suppres~ion Chamber Vacuum Breakers 6 3.6.1.5 BASES SURVEILLA~CE REQUIREMENTS SR 3.6.1.5.5

(~ontinued)

Each vacuum breaker must be cycled to ensure that it opens properly to perfom its design function and returns to its fully closed position. This ensures that the safety analysis assumptions are valid. The 92 day Frequency of this SR was developed based upon Inservice Testing Program require~nt~

to perfom valve testing at least once every 92 days.

SR 3.6.1*5.6 Demonstrat ion of air operated vacuum. breaker openi ng setpoint is necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of 1; 0.75 psid is valid. The 18 month Frequency i s based on requirements associated with the instruments that monitor differential pressure between the reactor building and suppression chamber and that this Surveillance can be performed while the plant is operating.

18 Fonth Frequency has been shown to be acceptable, based on operating experience. Operating experience has shown that these components usual ly pass the survei 11 ance when 18 month frequency, is further justified r surveil1 ances perfo at short t convey the proper functioning st For this unit, the each vacuum breaker.

SR 3.6.1.5.7 This SR ensures that in case the non-safety grade instrument air system is unavailable, the SGIG System will perform its design function to supply nitrogen gas at the required pressure for valve operators and valve seal s supported by the S616 System. The 24 month Frequency was developed considering it is prudent that this Surveillance be p e r f o ~ d only during a plant outage. Operating experience has shown that these components will usually pass this Surveil 1 ance when performed at the 24 month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES PBAPS UNIT 2 6 3.6-41 Revision No.

Suppression ~hamber-to-Dr~e~

1 Vacuum Breakers B 3.6.1.6 BASES ACTIONS

&J, (continued) because a single failure in one of the remaining vacuum breakers could result in an excessive suppression chamber-to-drywell differential pressure during a DBA, Therefore, with one o f the nine required vacuum breakers inoperable, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to restore the inoperable vacuum breaker to OPERABLE status with those assumed 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Compl et i on low probabil i ty o f breaker capabi 1 5 ty so that plant conditions are consistent for the design basis analysis. The Time is considered acceptable due to the an event in which the remaining vacuum would not be adequate.

An open vacuum breaker allows c~~unication between the drywell and suppression chamber airspace, and, as a result, there is the potential for suppression chamber overpressurization due to this bypass leakage if a LOCA were to occur. Therefore, the open vacuum breaker must be closed. A short time i s allowed to close the vacuum breaker due to the low probability of an event that would pressurize primary containment, is not reliable, an alternate method of verifying that the vacuum breakers are closed must be performed within 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , A1 1 suppression chamber-to-drywell vacuum breakers are considered closed, even if the "not fully seated" indication is shown, if a leak test confirms that the bypass area between the drywell and suppression chamber is less than or equivalent to a one-inch diameter hole (Ref, 1).

The required 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months Completion Time is considered adequate to perform this test. If the leak test fails, not only must the Actions be taken (close the open vacuum breaker within 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months ), but a1 so the appropriate Condition and Required Actions of LCO 3.6.lelV Primary If vacuum breaker position indication ment, must be entered, (continued)

PBAPS UNIT 2 B 3.6-45 Revision No,

Suppression Chamber-to-Drywel 1 Vacuum Breakers 6 3.6.1,6 i

ACTIONS (cont i nued)

MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The a1 1 owed Compl et i on Times are reasonable, based on operat i ng experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging pl ant systems,

SURVEILLANCE SR 3.6.1.6.1 R E Q ~ I R E M E ~ S Each vacuum breaker is verified closed to ensure that this potential large bypass leakage path is not present. This Surveil1 ance is performed by observing the vacuum breaker position indication or by performing a leak test that confirms that the bypass area between the drywell and suppression chamber i s less than or equivalent to a one-inch diameter hole.

If the bypass test fails, not only must the vacuum breaker($) be considered open and the appropriate Conditions and Required Actions of this LCO be entered, but also the appropriate Condition and Required Action of LCO 3.6,f.l must be entered. The 14 day Frequency i s based on engineering judgment, is considered adequate in view o f other indications of vacuum breaker status available to operations personnel, and has been shown to be acceptable through operating experience.

A Note is added to this SR which allows suppression chamber-to-drywell vacuum breakers opened in conjunction with the performance o f a Surveillance to not be considered as failing this SR. fhese periods of opening vacuum breakers are controlled by plant procedures and do not represent i noperabl e vacuua breakers.

SR 3.6.1.62 Each required vacuum breaker must be cycled t o ensure that it opens adequately to perfom its design function and returns to the fully closed position. This ensures that the safety analysis assumptions are valid.

The 31 day Frequency o f t h i s SR was developed, based on Inservice Testing Program requirements to perform valve testing at least once every 92 days. A 31 day Frequency was chosen to provide additional assurance that the vacuum breakers are OPERABLE, since they are located in a harsh environ~nt (the suppression chamber airspace),

PBAPS UNIT 2 B 3,6-46 Revision No.

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.6 BASES SURVEILLANCE SR 3.6.1.6.3 REQUIRE~ENTS (cont i nued 1 Verification of the vacuum breaker setpoint for f u l l opening i s necessary t o ensure t h a t the safety analysis assumption regarding vacuum breaker full open differential pressure of 0.5 psid i s valid.

The 24 month Frequency i s based on the need t o perform t h i s Surveillance under the conditions t h a t apply during a plant outage a n d the potential for a n unplanned transient i f the Surveillance were performed with the reactor a t power.

For t h i s f a c i l i t y, the 24 m o n t h Frequency has been shown t o be acceptable, based on operating experience, and i s further j u s t i f i e d because of other surveillances performed a t shorter Frequencies t h a t convey the proper functioning status of each vacuum breaker.

REFERENCES

1.

Safety Evaluation by the Office o f Nuclear Reactor Regulation Supporting Amendment Nos. 127 and 130 t o Faci 1 i t y Operating License Nos. DPR-44 and DPR-56, dated February 18, 1988.

PBAPS UNIT 2 B 3.6-47 Revi s-i on No.

RHR Suppression Po01 Cool ing B 3,6,2.3 BASES overall reliability is reduced because a single failure in the O P E ~ B L E subsystem could result in reduced primary

~ o n t a i n ~ n t cooling capability, The 7 day Completion Time is acceptable in light of the redundant RHR suppression pool cooling capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period, With two RHR suppression pool cooling subsystems inoperable, one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

In this condition, there is a substantial loss o f the primary containment pressure and temperature mi tigation function, The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Com~letion Time is based on this loss of function and is considered acceptable due to the low probability of a DBA and because alternative methods to heat from primary containment are av least MOOE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to BODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , The a1 1 owed Compl et ion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without chal 7 engi ng pl ant systems, SURVEILLANCE R E ~ U I R E ~ E ~ ~ ~

Verifying the correct a1 ign~ent for manual, power operated, and automatic valves in the RHR suppression pool cooling mode flow path provides assurance that the proper flow path exists for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within PBAPS UNIT 2 8 3.6-58 Revision No,

RHR Suppression Pool Cool ing B 3.6.2.3 BASES SURVEILLANCE SR 3.6.2.3.1 (continued)

REQUI~E~ENTS the time assumed i n the accident analysis.

This i s acceptable since the RHR suppression pool cooling mode i s manually initiated.

This SR does not require any testing or valve manipulation^ rather, it involves v e r i f i c a t i o n that those valves capable o f being mispositioned are i n the correct position.

This SR does not apply t o valves that cannot be inadvertently misaligned, such as check valves.

The Frequency o f 31 days i s j u s t i f i e d because the valves are operated under procedural control I improper valve position would affect only a single subsystem, the probability o f an event requiring i n i t i a t i o n o f the system i s lowI and the subsystem i s a manually i n i t i a t e d system.

This Frequency has been shown t o be acceptable based on operating exper i ence.

SR 3.6.2.3.2 Verifying that each required RHR pump develops a flow rate zr 10,000 gpm while operating i n the suppression pool cooling mode with flow through the associated heat exchanger ensures that pump performance has not degraded during the cycle.

flow i s a normal t e s t o f centrifugal pu required by ASHE Code,Section X I (Ref.

confirnos one point on the pump design c are indicative o f overall performance.

Such inservice inspections confirm component ~ P E ~ ~ I L I ~ Y,

trend performance, and detect incipient failures by indicating.

abnormal performance.

The Frequency o f t h i s SR i s i n accordance with the Inservice Testing Program.

. UFSAR, Section 14.6.3.

ASME, Boiler and Pressure Vessel Code,Section XI.

PBAPS UNIT 2 B 3.6-59 Revision No.

RHR Suppression Pool Spray B 3.6.2.4 BASES (con t i nued)

ACT IONS A

A 1 With one RHR suppression pool spray subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining OPERABLE RWR suppression pool spray subsystem is adequate to perform the primary containment bypass leakage mi tigation function.

However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containknt bypass mitigation capability. The 7 day Completion Time was chosen in light of the redundant RHR suppression pool spray capabil i ties afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.

With both RHR suppression pool spray subsystems inoperable, at least one subsystem must be restored to O P E ~ B L E status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In this Condition, there i s a substantial loss of the primary containment bypass leakage mitigation function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is based on this loss o f function and is considered acceptable due to the low probability o f a DBA and because alternative methods to remove heat from primary containment are available.

If the inoperable RHR suppression pool spray subsyste cannot be restored to OPERABLE status within the associated t be brought to a MODE in ast MODE 3 within 12 llowed Completion Tim To achieve this status, the experience, to reach the full power conditions in an orderly manner and without challenging plant systems.

SURVEI LLANCE SR 3.6.2.4.1 REQUIRE~ENTS Verifying the correct a1 i g n ~ n t f o r manual power operated, and automatic valves in the RHR suppression pool spray mode flow path provides assurance that the proper flow paths will (cont inuedl PBAPS UNIT 2 B 3.6-62 Revision No.

RHR Suppression Pool Spray B 3.6,2.4 BASES SURVE I L LANC E SR 3.6.2.4.1 (continued)

REQUIRE~ENTS exist for system operation.

This SR does not apply t o valves that are locked, sealed, o r otherwise secured i n position since these valves were verified t o be i n the correct position prior t o locking, sealing, or securing.

A valve i s also allowed t o be i n the nonaccident position provided it can be aligned t o the accident position within the time assumed i n the accident analysis.

This i s acceptable since 'the RHR suppression pool cooling mode i s manually initiated, This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable o f being mispositioned are i n the correct position.

This SR does not apply t o valves that cannot be inadvertently noisal igned, such as check valves, The Frequency o f 31 days i s j u s t i f i e d because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability o f an event requiring i n i t i a t i o n o f the system i s low, and the subsystem i s a manually initiated system.

This Frequency has been shown t o be acceptable based on operating experience.

R 3.62.4.2 This Surveillance i s performed every 10 years t o v e r i f y that the spray nozzles are not obstructed and that flow w i l l be provided when required.

The 10 year Frequency i s adequate t o detect degradation i n performance due t o the passive nozzle design and i t s normally dry state and has been shown t o be acceptable through operating experience.

1.

UFSAR, Sections 5.2 and 14.6.3.

PBAPS UNIT 2 B 3.6-63 Revision No.

Secondary Containment B 3.6.4.1 BASES ACT IONS (continued)

If secondary containment cannot be restored to OPERABLE CJ. C.2. and C.3 Movement o f irradiated fuel assemblies in the secondary containment, CORE ALTE~TIO~S, and OPDRVs can be postulated to cause fission product release to the secondary containment. In such cases, the secondary containment is the only barrier to release of fission products to the environment. CORE A L T E ~ T I O ~ S and movement o f irradiated fuel assemblies must be imnediately suspended if the secondary containment i s inoperable.

Suspension o f these activities shall not preclude completing an action that involves moving a component to a safe position. Also, action must 'be imnediately initiated to suspend OPDRVs to mini ize the probabil ity of a vessel draindown and subsequent potential for fission product re1 ease. Actions must continue unt i 1 OPDRVs are suspended.

Required Action C.1 has been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is inde~endent o f reactor operations. Therefore, in either case, inability to suspend move~nt o f irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

PBAPS UNIT 2 B 3.6-75 (continued)

Revision No.

Secondary Containment B 3.6.4.1 BASES S U R V E I L L A N ~ E SR 3.6.4.1.3 a n d SR 3.6.4.1.4 (continued)

R E Q ~ I R E ~ ~ ~ T S seconds using one SGT subsystem.

SR 3.6.4.1.4 demonstrates t h a t the pressure in the secondary containment can be maintained 2 0.25 inches of vacuum water gauge for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months using one SGT subsystem a t a flow rate.s 10,500 cfm. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months t e s t period allows secondary containment t o be in thermal equilibrium a t steady s t a t e conditions.

The primary purpose of these SRs i s t o ensure secondary containment boundary integrity.

The secondary purpose of these SRs i s t o ensure t h a t the SGT subsystem being tested functions as designed.

There i s a Separate LCO w i t h Surveillance Requirements which serves the primary purpose of ensuring OPERABLITY o f the SGT System.

These SRs need n o t be performed with each SGT subsystem.

for these Surveillances i s staggered t o ensure t h a t in addition t o the requirements o f LCO 3.6.4.3, either SGT subsystem will perform t h i s t e s t. The inoperability of the SGT System does not necessarily constitute a f a i l u r e of these Surveillances relative t o the secondary containment O P E R A B I L I T Y. Operating experience has shown the secondary containment boundary usually passes these Surveillances when performed a t the 24 month Frequency.

Therefore, the Frequency was concluded t o be acceptable from a r e l i a b i l i t y standpoint.

The SGT subsystem used REFERENCES

1.

UFSAR, Section 14.6.3.

2.

UFSAR, Section 14.6.4.

PBAPS UNIT 2 B 3.6-77 Revision No.

SGT System B 3.6.4.3 BASES LCO For Unit 2, one SCT subsystem i s OPE~BLE when one charcoal f i l t e r train, one fan (OAVOZO) and associated ductwork, dampers, valves, and controls are OPERA~LE. The second SGT subsystem i s OPERABLE when the other charcoal f i l t e r train, one fan (OBVO20) and associated ductwork, damper, valves, and controls are OPERABLE.

(cont i nued)

APPL I CAB I L I TY I n MODES 1, 2, and 3, a DBA could lead t o a f i s s i o n product release t o primary containment that leaks t o secondary containment. Therefore, SGT System OPERABILITY i s required during these MODES, I n MODES 4 and 5, the probability and consequences o f these events are reduced due t o the pressure and temperature limitations i n these NODES.

Therefore, maintaining the SGT System i n OPERABLE status i s not required i n MODE 4 o r 5, except f o r other situations under which s i g n i f i c a n t releases o f radioactive material can be postulated, such as during operations with a potential f o r draining the reactor vessel (OPDRVs) during CORE ALTE~TIO~S, o r during movement o f irradiated fuel assemblies i n the secondary containment ACTIONS A,1 With one SGT subsystem inoperable, the inoperable subsystem must be restored t o OPERABLE status i n 7 days.

Condition, the remaining OPERABLE SGT subsystem i s adequate t o perform the required radioactivity release control function.

However, the overall system r e l i a b i l i t y i s reduced because a single f a i l u r e i n the OPERABLE subsystem could result i n the radioactivity release control function not being adequately performed.

The 7 day Completion Time i s based on consideration o f such factors as the a v a i l a b i l i t y o f the OPERABLE redundant SGT subsystem and the In t h i s low probabilfty o f a DBA occurring during If the SGT subsystem cannot be restored t o OPERABLE status within the required Completion must be brought t o a MODE To achieve t h i s status, s t MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months k o n t i nued)

PBAPS UNIT 2 B 3.6-87 Revision No.

SGT System B 3.6.4.3 BASES (eont i nued)

The a7 7 owed Compl et i on Time perating experience, to reac from full power conditions in an orderly manner and without challenging plant systems, C.1, C.2.1, C.2.2, and C.2.3 During movement of irradiated fuel assemblies, in the secondary contain~nt, during CORE A L T E ~ T I O ~ S,

or during OPDRVs, when Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE SGT subsystem should immediately be placed in operation. This action ensures that the remaining subsystem is OPERABLE, that no failures that could prevent automatic actuation have occurred, and that any other failure would be readily detected.

An alternative to Required Action C.1 is to immediately suspend activities that represent a potential for releasing radioactive material to the secondary containment, thus placing the plant in a condition that minimizes risk.

applicable, CORE ALTERATIONS and ~ v e m e n t o f irradiated fuel 1ude ~ompletjon of movement of a component to a safe position. Also, if applicable, actions must immediately be initiated to suspend OPDRVs i n drder to minimize the probability o f a vessel draindown and subsequent potential for fission product release, Actions must continue until OPDRVs are suspended.

I f must immediately suspended. Suspension of ities must not p The Required Actions o f Condition C have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action, If moving irradiated fuel assemblies while in WOE 1, 2, or 3, the fuel movement is independent o f reactor operations. Therefore, in either case, inability to suspend movement o f irradiated fuel assemblies would not be a sufficient reason t o require a reactor shutdown.

(con t i nued 1 PBAPS UNIT 2 B 3.6-88 Revision No.

SGT System B 3.6.4.3 BASES ACTIONS D.1

(~ontinued)

E.1.

f.2. and E.3-When two SGT subsystems are inoperable, if applicable, CORE A L T E ~ T I O ~ S and movement of irradiated fuel assemblies in secondary containment must i~ediately be suspended.

Suspension of these act iv0 t i es shall not precl ude compl et i on of movement of a component to a safe posftion. Also, if applicable, actions must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product re1 ease. Actions must cont i nue unt i 1 OPDRVs are suspended.

Required Action E.1 has been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in HOD 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while i n DE 1, 2, or 3, the fuel 1 ~ 0 ent is independent of reactor operations. Therefore, in e r case, inability to suspend movement of irradiated fuel sufficient reason to require a reactor shutdown.

bl ies would not be a SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 Operating each SGT subsystera (including each filter train fan) for L 15 minutes ensures that both subsystems are OPERASLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vtbration can be detected for corrective action. Operation with the heaters on ( a u t ~ ~ a t i ~

heater cycling to maintain temperature) for 2 15 minutes every 31 days is sufficient to eliminate moisture on the adsorbers and HEPA filters since during idle periods instrument air is injected into the filter plenu~ to keep the filters dry. The 31 day Frequency was developed in consideration of the known reliability o f fan motors and controls and the redundancy available in the system.

PBAPS UNIT 2 B 3.6-89 Revision No.

SGT System 6 3.6.4.3 BASES SURVEILLANCE SR 3.6,4.3.2 R E Q U I R E ~ E N T S (continued)

T h i s SR v e r i f i e s t h a t t h e r e q u i r e d SGT f i l t e r t e s t i n g i s performed i n accordance w i t h t h e V e n t i l a t i o n F i l t e r T e s t i n g Program (VFTP).

The VFTP i n c l u d e s t e s t i n g HEPA f i l t e r performance, c h a r c o a l adsorber e f f i c i e n c y, minimum system f l o w r a t e, and t h e p h y s i c a l p r o p e r t i e s o f t h e a c t i v a t e d charcoal (general use and f o l l o w i n g s p e c i f i c o p e r a t i o n s ).

S p e c i f i c t e s t f r e q u e n c i e s and a d d i t i o n a l i n f o r m a t i o n a r e discussed i n d e t a i l i n t h e VFTP.

SR 3.6.4.3.3 T h i s SR v e r i f i e s t h a t each SGT subsystem s t a r t s on r e c e i p t o f an a c t u a l o r s i m u l a t e d i n i t i a t i o n s i g n a l.

While t h i s S u r v e i l l a n c e can be performed w i t h t h e r e a c t o r a t power, o p e r a t i n g experience has shown t h a t these components w i l l u s u a l l y pass t h e S u r v e i l l a n c e when performed a t t h e 24 month Frequency.

The LOGIC SYSTEM FU~CTIONAL TEST i n LCO 3.3.6.2, "Secondary Containment Is01 a t i o n I n s t r u m e n t a t i o n, " over1 aps t h i s SR t o p r o v i d e compfete t e s t i n g o f t h e s a f e t y f u n c t i o n.

Therefore, t h e Frequency was found t o be acceptable f r o m a r e 1 i a b i 1 i t y s t a n d p o i n t.

REFERENCES

1.

UFSAR, S e c t i o n 1.5.1.6.

I

2.

UFSAR, S e c t i o n 14.9.

PBAPS U N I T 2 6 3.6-90 R e v i s i o n No.

HPSW System B 3.7.1 BASES ACTIONS (continued) could result in loss of HPSW function. The Completion Time is based on the redundant HPSW capabilities afforded by the OPERABLE subsystem and the low probability of an event occurring requiring HPSW during this period.

The Required Action is modified by a Note indicating that the applicable Conditions of K O 3.4.7, be entered and Required Actions taken if an inoperable HPSW subsystem results in an inoperable RHR shutdown cooling subsystem.

This is an exception to K O 3.0.6 and ensures the proper actions are taken for these components.

With both HPSW subsystem inoperable, the HPSW System i s not capable o f performing its intended function. At least one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

subsystem to OPERABLE status, is based on the Completion Times provided for the RHR suppression pool cooling and spray functions.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time for restoring one HPSW red Action is cable Conditio by a Note indicating that 3.4.7, be entered and Required Actions taken if an inoperable HPSW subsystem results in an inoperable RHR shutdown cooling subsystem.

This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

If the HPSW subsystems cannot be r to OPERABLE status within the associated Completion T e unit must be placed in a NODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Tiares are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

PBAPS UNIT 2 (continued)

Revision No.

B 3.7-4

HPSW System B 3-7.1 BASES onti tin^^^)

SURVEILLA~CE REQUIREMENTS SR 3.7.L]L Verifying the correct align~ent for each manual and power operated valve in each HPSW subsystem flow path provides assurance that the proper flow paths will exist for HPSW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position, and yet considered in the correct position, provided it can be rea'ligned to its accident position. This is acceptable because the HPSW System is a manually initiated system.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable o f being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls govern4 ng valve operation, and ensures correct valve positions.

REFERENCES

1.

UFSAR, Section 10.7.

2.

UFSAR, Chapter 14.

3, NEDC-32183P, "Power Rerate Safety Analysis Report For Peach Bottom 2 & 3," May 1993.

4, UFSAR, Section 14.6.3.

PBAPS UNIT 2 B 3,795 Revision No.

ESW System and Normal Heat Sink B 3.7.2 BASES SURVEILLAN~E SR 3.7.2.4 REQU I RE~ENTS (cont i nued)

This SR verifies that the ESW System pumps will 4 automatically start to provide cooling water to the required safety related equipment during an accident event, This is demonstrated by'the use of an actual or simulated initiation signal.

Operating experience has shown that these components will usually pass the SR when performed at the 24 month Frequency. Therefore, this Frequency is concluded to be acceptable from a reliability standpoint, REFERENCES 1,

UFSAR, Chapter 14, f

PBAPS UNIT 2 6 3.7-10 Revision No.

MCREV System B 3.7.4 BASES ACTIONS (cont i nued) result in reduced MCREV System capability. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and that the remaining subsystem can provide the required capabilities.

In MODE 1, 2, or 3, if the inoperable MCREV subsystem cannot be restored to OPERABLE status within the associated lime, the unit must be placed in a HODE that risk. To achieve this status, MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months The a1 1 owed Compl et i on on operating experience itions from full power conditions in an wi thaut chall engi ng unit systems.

C.1. C.2.1, C.2.2.

and C.2.3 The Required Actions of Condition C are modified by a Note indicating that LCO 3.0.3 does not apply.

irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel ~ v e ~ n t is independent o f reactor operations.

Therefore, inability to suspend movement o f irradiated fuel assemblies is not sufficient reason to require a reactor

shutdown, If moving During movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs, if the inoperable MCREV subsystem cannot be restored to OPERABLE status within the required Co~pletion Time, the

~ P E ~ ~ L E MCREV subsystem may be placed in operation. This action ensures that the remaining subsystem is O P E ~ B ~ E,

that no failures that would prevent automatic actuation will occur, and that any active failure will be readily detected.

An alternative to Required Action C.1 is to immediately suspend activities that present a potential for releasing radioactivity that aright require isolation of the control room, This places the unit in a condition that minimizes risk.

kont i nued 1 PBAPS UNIT 2 B 3.7-18 Revision No.

HCREV System B 3.7.4 BASES ACTIONS C.1. C 2. 1. C.2.2.

and C.2.3 (continued)

If applicable, CORE ALTE~TIONS and ~ovement of irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension o f these activities shall not preclude completion o f movement of a component to a safe position. Also, if applicable, actions must be initiated i ~ d i a t e l y to suspend OPDRVs to minimize the probability of a vessel draindoyn and the subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

If both MCREV subsystems are inoperable in MODE 1, 2, or 3, E d. F 2. and E.3 The ~equired Actions o f Condition E are modified by a Note indicating that LCO 3.0.3 does not apply.

irradiated fuel assemblies le in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

Therefore, inability to suspend movement o f irradiated fuel assemblies i s not sufficient reason to require a reactor shutdown.

If moving During move~ent of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs, with two HCREV subsystems inoperable, action must be taken immediately to suspend activities that present a potential for releasing radioactivity that might require isolation o f the control room. This places the unit in a condition that minimizes risk.

If applicable, CORE A ~ T E ~ T I O N S and movement o f irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension o f these activities shall not preclude completion o f movement of a component to a safe position. If applicable, actions must be initiated (continued)

PBAPS UNIT 2 B 3.7-19 Revision No.

MCREV System B 3.7.4 BASES SURVEILLANCE SR 3.7.4.4 REQU I REMENTS (continued)

This SR v e r i f i e s the i n t e g r i t y o f the control room enclosure, and the assumed inleakage rates o f p o t e n t i a l l y contaminated a i r.

The control room positive pressure, with respect t o potentially contaminated adjacent areas (the turbine building), i s periodically tested t o v e r i f y proper function o f the MCREV System.

During operation, the MCREV System i s designed t o s l i g h t l y pressurize the control room 2 0.1 inches water gauge positive pressure with respect t o the turbine building t o prevent u n f i l t e r e d inleakage.

The MCREV System i s designed t o provide t h i s p o s i t i v e pressure a t a flow r a t e o f 2 2700 cfm and s 3300 cfm t o the control room when i n operation.

Manual adjustment o f the MCREV System may be required t o establish the flow r a t e o f 2 2700 cfm and s 3300 cfm during SR performance.

The Frequency o f 24 months on a STAGGERED TEST BASIS i s consistent with other f i l t r a t i o n systems SRs.

I REFERENCES

1.

UFSAR, Section 7.19.

2.

UFSAR, Section 10.13.

3.

UFSAR, Section 12.3.4.

4.

UFSAR, Section 14.9.1.5.

PBAPS UNIT 2 B 3.7-21 Revision No.

Plain Condenser Offgas B 3.7.5 BASES LCO with t h i s requirement (3293 MWt x l O O ~ i / ~ t - s e c o n d

=

320,000, Nilsecond) and i s based on the original licensed rated thermal power.

(continued)

APPLICABILITY The LCO i s applicable when steam i s being exhausted t o the main condenser and the resulting noncondensi bles are being processed v i a the Main Condenser Offgas System.

This occurs during HODE 1, and during MODES 2 and 3 with any main steam l i n e not isolated and the SJAE i n operation.

and 5, steam i s not being exhausted t o the main condenser and the requirements are not applicable.

I n MODES 4 ACT IONS A.1 If the offgas radioactivity rate l i m i t i s exceeded, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months i s allowed t o restore the gross gamma a c t i v i t y r a t e t o within the l i m i t.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time i s reasonable, based on engineering judgment, the time required t o complete the Required Action, the large margins associated with permissible dose and exposure 1 i m i ts, and the low probability o f a Main Condenser Offgas System rupture.

If the gross gamna a c t i v i t y rate i s not restored t o within the l i m i t s i n the associated Completion Time, a l l main steam l i n e s or the SJAE must be isolated, This isolates the Main Condenser Offgas System from the source o f the radioactive steam.

The main steam l i n e s are considered isolated i f a t least one main steam isolation valve i n each main steam l i n e i s closed, and a t least one main steam l i n e drain valve i n each drain l i n e inboard o f the main steam isolation valves i s closed.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time i s reasonable, based on operating experience, t o perform the actions from f u l l power conditions i n an orderly manner and without chall enging unit systems.

a1 1 owed Compl e t i on T i PBAPS UNIT 2 B 3,7023 Revision No.

Main Condenser Offgas B 3.7.5 BASES ACTIONS (continued) experience, to reach the required unit conditions from full power conditions in an orderly manner and without chal 1 engi ng unit systems.

S URV E I L LANC E SR 3.7.5.1 R E Q U I R E ~ E ~ T S This SR, on a 31 day Frequency, requires an isotopic analysis of an offgas sample to ensure that the required limits are satisfied. The noble gases to be sampled are Xe-133, Xe-135, Xe-138, KrO85m, Kr-87, and Kr-88. If the measured rate of radioactivity increases significantly (by a 50% after correcting for expected increases due to changes in J H E ~ l POWER), an isotopic analysis is also performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the increase is noted, to ensure that the increase is not indicative of a sustained increase in the radioactivity rate, The 31 day Frequency is adequate in view of other instrumentation that continuously monitor the of fgas, and i s acceptabl e, based on operating experi ence.

This SR is modified by a Note indicating that the SR is not required to be performed until 31 days after any main steam line is not isolated and the SJAE is in operation. Only in this condition can radioactive fission gases be in the Main Condenser Offgas System at significant rates.

REFERENCES

1.

UFSAR, Section 9.4.5.

2.

10 CFR 100, PBAPS UNIT 2 6 3.7-24 Revision No.

AC Sources-Operating B 3.8.1 BASES ACT IONS f.l (continued)

With two or more DGs inoperable, with an assumed loss o f offsite electrical power, insufficient standby AC sources are available to power the minimum required ESF functions.

Since the offsite electrical power system is the only source of AC power for the majority o f ESF equip~nt at this level of degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown. (The immediate shutdown could cause grid instability, which could result in a total loss of AC power.)

Since any inadvertent unit generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level o f degradation.

According to Regulatory Guide 1-93 (Ref. 6), with two or more DGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

(Regulatory Guide L 9 3 assumed the unit has two DGs, Thus, a loss of both DGs results in a total loss o f onsite power, Therefore, a loss o f more than two DGs, in the Peach Bottom etomic Power Station design, results in degradation no worse than that assumed in Regulatory Guide 1.93,)

If the inoperable AC electrical power source(s) cannot be restored to OPERABLE status within the associated Completion Time (Required Action and associated Completion Time of Condition A, C, 0, E, or F not met; or Required Action B.2, 2,

or 8.5 and associated Completion Time not must be brought to a MODE i To achieve this status, th t MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months The allowed Completion Ti on operating experience, ditions from full power conditions in an without challenging plant systems.

PBAPS UNIT 2 B 3,8017 Revision No.

AC Sources-Operat i ng B 3.8.1 BASES SURVEILLANCE SR 3.8.1.21 (continued)

REQ~IRE~EN~S Unit 3 Technical Specifications exempts performance o f a Unit 3 SR (However, as stated i n the Unit 3 SR 3.8.2.1

Note, while performance o f an SR i s exempted, the SR s t i l l must be met) 0 REFERENCES 1..

UFSAR, Sections 1.5 and 8.4.2.

2.

3.

40

5.

6.

7.

8.

9.

UFSAR, Sections 8.3 and 8.4.

Regulatory Guide 1.9, July 1993.

UFSAR, Chapter 14.

Generic Letter 84-15.

Regulatory Guide 1.93, December 1974.

UFSAR, Section 1.5.1.

Regul atory Guide 1.108, August 1977.

Regulatory Guide 1.137, October 1979.

10.

UFSAR, Section 8.5.

PBAPS UNIT 2 B 3.8-39 Revision No.

DC Sources-Operating B 3.0.4 BASES ACT IONS The a1 1 owed Conipl et i r

E l Condition E corresponds to a level o f degradation in the DC electrical power subsystems that causes a required safety function to be lost. When mare than one DC source is lost, this results in a loss o f a required function, thus the plant i s in a condition outside the accident analysis.

Therefore, no additional time i s justified for continued operation. LCO 3 A - 3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE REQU I REMENTS As Noted at the beginning of the SRs, SR 3.8.4.1 through SR 3.8.4.8 are applicable only to the Unit 2 DC electrical power subsystems and SR 3.8.4.9 i s applicable only to the Unit 3 DC electrical power subsystems.

SR 3.8.4.1 Verifying battery terminal voltage while on float charge for the battertes helps to ensure the effectiveness of the charging system and the ability o f the batteries to perform their intended function. Float charge is the condition in which the charger i s supplying the continuous charge required to overcome the internal losses o f a battery (or battery cell) and maintain the battery (or a battery cell) in a fully charged state. The voltage requirements are (cont i nued 1 PBAPS UNIT 2 6 3.8-64 Revision No.

DC Sources-Operating B 3.8.4 BASES REFERENCES 4,

Regulatory Guide 1.93, December 1974.

(continued)

5.

IEEE Standard 450, 1987.

PBAPS UNIT 2 B 3.8-71 Revision No.

Di s tr i but i on Systems -Opera t i ng B 3.8.7 BASES ACTIONS D.1 (continued)

This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage timi! "dock."

This allowance results in establishing the "time zero" at the time LCO 3.8.7.a was initially not met, instead o f at the time Condition D was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time i s an acceptable l i itation on this potential of failing to meet the K O indefinitely.

If the inoperable electrical power distribution subsystem cannot be restored to OPERABLE status within the associated F.1 Condition F corresponds to a level of degradation in the electrical power distribution system that causes a required safety function to be lost, When more than one Condition is entered, and this results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation, LCO 3.0.3 must be entered immediately to 'commence a controlled shutdown.

SURVEr L

~

A

~

E SR 3.8.7.1 RE~UIRE~ENTS This Surveillance verifies that the AC and DC electrical power distribution systems are functioning properly, with the correct circuit breaker alignment (for the AC electrical power distribution system only),

The correct AC breaker a1 ignment ensures the appropriate separation and independence o f the electrical buses are maintained, and power i s available to each required bus. The verification o f indicated power availability on the AC and DC buses PBAPS UNIT 2 B 3.8-91 Revision No,

Distribution Systems-Operating B 3.8.7 BASES SR 3.8.7.1 (continued) ensures that the required power i s readily available f o r motive as well as control functions for critical system loads connected to these buses, This may be performed by verification of absence of low voltage alarms. The 7 day Frequency takes into account the redundant capability o f the AC and DC electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES 1,

UFSAR, Chapter 14,

2.

Regulatory Guide 1.93, December 1974, PBAPS UNIT 2 B 3,8092 Revision No.

RPS Electric Power Monitoring B 3.3.8.2 BASES ACTIONS B.1 (continued)

The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is sufficient for the plant operations personnel to take corrective actions and is acceptable because it minimizes risk while allowing time for restoration or removal from service of the electric power m~nitoring assemblies.

Alternately, if it is not desired to remove the power supply(s) from service (e.g., as in the case where removing the power supply(s) from service would result in a scram or isolation), Condition C or D, as applicable, must be entered and its Required Actions taken.

D. 1 If any Required Action and associated Completion Time of Condition A or B are not met in MODE 3, 4, or 5 with any control rod withdrawn from a core ceJ7 containing one or more fuel assemblies, the operator must immediately initiate action to fully insert all insertable control rods in core cells containing one or more fuel assemblies. Required Action D.1 results in the least reactive condition for the reactor core and ensures that the safety function of the RPS (e.g., scram o f control rods) is not required.

PBAPS UNIT 3 B 3.3-203 (continued)

Revision No.

RPS E l e c t r i c Power Monitoring B 3.3.8.2 BASES SURVEILLANCE REQUIREMENTS SR 3.3.8.2.4 (continued) per power monitoring assembly i s required t o be tested.

This Surveillance overlaps w i t h the CHANNEL C A L I 6 ~ T I ~ N t o provide complete testing o f the safety function.

The system functional t e s t o f the Class 1E c i r c u i t breakers i s included as part o f t h i s t e s t t o provide complete t e s t i n g o f the safety function.

operating, the associated e l e c t r i c power monitoring assembly would be i noperabl e.

If the breakers are incapable o f The 24 month Frequency i s based on the need t o perform t h i s Surveillance under the conditions that apply during a plant outage and the potential f o r an unplanned transient i f the Surveillance were performed with the reactor a t power.

Operating experience has shown that these components w i l l pass the Surveillance when performed a t the 24 month Frequency.

REFERENCES

1.

UFSAR, Section 7.2.3.2.

2.

NRC Generic Letter 91-09, "Modification o f Surveillance Interval f o r the E l e c t r i c a l Protective Assemblies i n Power Supplies for the Reactor Protection System."

PBAPS UNIT 3 B 3.3-205 Revision No.

SRVs and SVs B 3.4.3 BASES S U R V E ~ L L A N ~ E SR 3.4.3.2 REQUIRE~ENTS (cont i nued)

The pneumatic actuator of each SRV valve is stroked to verify that the second stage pilot disc rod is mechanically displaced when the actuator strokes.

movement is determined by the measurement of actuator rod travel. The total amount of movement o f the second stage pilot rod from the valve closed position to the open position shall meet criteria established by the SRV supplier.

failure o f the solenoid, but is capable of opening on overpressure, the safety function o f the SRV i s considered OPERABLE.

Second stage pilot rod If the valve fails to actuate due only to the Operating experience has shown that these components will pass the SR when performed at the 24 month Frequency, which is based on the refueling outage. Therefore, the frequency was concluded to be acceptable from a reliability standpoint.

REFERENCES 1

NEDC-32183P, Power Rerate Safety Analysis Report for Peach Bottom 2 & 3, May 1993.

PBAPS UNIT 3 8 3.4-18 Revision No.

BASES ECCS-Operat i ng B 3.5.1 ACT IONS (continued)

If the inoperable low pressure ECCS subsystem cannot be required plant conditions from full power conditions in orderly manner and without challenging pl ant systems.

C.1 and C.2 If the HPCI System is inoperable and the RCIC System is i~ediately verified to be OPERABLE, the HPCI System must be restored to OPERABLE status within 14 days.

Condition, adequate core cooling is ensured by the OPE~6ILIlY o f the redundant and diverse low pressure E N S injection/spray subsystems in conjunction with ADS.

Also, the RCIC System will automatically provide makeup water at most reactor operating pressures. Immediate verification o f RCIC O P E ~ B I L ~ T Y is therefore required when HPCI is inoperable. This may be performed as an administrative check by examining logs or other information to determine i f RCIC is out o f service for maintenance or other reasons. It does not mean to perform the Surveillances needed to demonstrate the OPE~BILI7Y o f the RCIC System.

OPERABILITY o f the RCIC System cannot be verified immediately, however, Condition E must be immediately entered, If a single active ~o~ponent f a i l s concurrent with a design basis LOCA, there is a potential, depending on the specific failure, that the m i n i ~ u ~

required ECCS eQuipment will not be available. A 14 day Completion Time is based on a reliability study cited in Reference 9 and has been found to be acceptable through operating experience.

In this If the D. l and 0.2 If any one 7 ow pressure ECCS inject i on/spray subsystem i s inoperable in addition to an inoperable HPCI System, the inoperable low pressure ECCS injection/spray subsystem or the HPCI System must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this Condition, adequate core cooling is (continued)

PBAPS UNIT 3 B 3.5-7 Revision No.

f

ECCS-Operating 6 3.5.1 BASES ACTIONS 0.1 and 0.2 (continued) ensured by the O P E ~ B I ~ I T Y o f the ADS and the remaining low pressure ECCS subsystems

.r However, the overall ECCS re1 iability is significantly reduced because a single failure in one of the remaining O P E ~ B L E subsystems concurrent with a design basis LOCA may result in the ECCS not being able to perform its intended safety function.

Since both a high pressure system (HPCI) and a low pressure subsystem are inoperable, a more restrictive Co~pletion Time o f 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is required to restore either the HPCI System or the low pressure ECCS injection/spray subsystem to OPERABLE status. This Completion Time is based on a reliability study cited in Reference 9 and has been found t o be acceptable through operating experience.

The LCO requires five ADS valves to be OPERABLE in order to provide the ADS function. Reference 7 contains the results o f an analysis that evaluated the effect o f one ADS valve being out of service. Per this analysis, operation of only four ADS valves will provide the required depressurization.

However, overall re1 i abi 1 i ty of the ADS i s reduced, because a single failure in the OPERABLE ADS valves could result in a reduction in depressurization capabil ity, Therefore, operation is only allowed for a limited time.

Completion Time is based on a reliability study cited in Reference 9 and has been found to be acceptable through operating experience.

The 14 day (continued)

PBAPS UNIT 3 B 3.5-8 Revision No.

ECCS-Operating B 3.5.1 BASES If any one low pressure ECCS injection/spray subsystem is inoperable in addition to one inoperable ADS valve, adequate core cool'ing is ensured by the OPE~BILITY o f HPCI and the remaining low pressure ECCS injection/spray subsystem.

However, overall ECCS reliability is reduced because a single active component failure concurrent with a design basis LOCA could result in the ~inimum required ECCS equipment not being available, system (ADS) and a low pressure subsystem are inoperable, a more restrictive Completion Time o f 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is required to restore either the low pressure ECCS subsystem or the ADS valve to OPERABLE status, This Completion Time i s based on a reliability study cited in Reference 9 and has been found to be acceptable through operating experience.

Since both a high pressure SURVEILLANCE SR 3.5.1.1 REQUIREMENTS The f l o w path piping has the potential to develop voids and pockets of entrained air, Maintaining the pump discharge lines of the HPCI System, CS System, and LPCI subsystems full of water ensures that the ECCS will perform properly, (continued)

PBAPS UNIT 3 B 3.5-9 Revision No.

ECCS-Operating B 3.5.1 BASES

( c o n t i n u e d )

REFERENCES

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

11.

UFSAR, S e c t i o n 6.4.3.

UFSAR, S e c t i o n 6.4.4.

UFSAR, S e c t i o n 6.4.1.

UFSAR, Sections 4.4.5 and 6.4.2.

UFSAR, S e c t i o n 14.6.

10 CFR 50, Appendix K.

NEDC-32163P, "Peach Bottom Atomic Power S t a t i o n U n i t s 2 and 3 SAFERlGESTR-LOCA Loss o f Coolant Accident A n a l y s i s, " January 1993.

10 CFR 50.46.

Memorandum f r o m R.L. Baer ( N R C ) t o V. S t e l f o, J r.

( N R C ),

"Recommended I n t e r i m Revisions t o LCOs f o r ECCS Components," December 1, 1975.

UFSAR, S e c t i o n 10.17.6.

I I s s u e Report 189167, O p e r a b i l i t y o f RHR w h i l e i n T e s t ModeslTorus Cooling.

PBAPS UNIT 3 B 3.5-17 R e v i s i o n No.

R G I C System B 3.5.3 I

BASES (continued)

\\

ACTIONS A Note p r o h i b i t s t h e a p p l i c a t i o n o f LCO 3.0.4.b t o an inoperable R C I C system.

i n t h e A p p l i c a b i l i t y w i t h an jnoperable R C I C systemland t h e other s p e c i f i e d c o n d i t i o n i n t h e A p p l i c a b i l i t y w i t h t h e LCO n o t met a f t e r performance o f a r i s k assessment addressing inoperable systems and components, should n o t be applied, i n t h i s c i rcumstance.

There i s an increased r i s k I

associated w i t h e n t e r i n g a MODE o r o t h e r s p e c i f i e d c o n d i t i o n p r o v i s i o n s o f LCO 3.0.4,b, w h i c h ' a l l o w e n t r y i n t o a MODE o r I

I Iti A. l and A.2 I f t h e R C I C System i s inoperable d u r i n g MODE 1, o r MODE 2 o r 3 w i t h r e a c t o r steam dome pressure > 150 p s i g, and t h e HPCI System i s immediately v e r i i f i e d t o be OPERABLEy t h e R C I C System must be r e s t o r e d t o OPERABLE,status w i t h i n 14 days.

I n t h i s Condition, l o s s o f t h e R C I C System w i l l n o t a f f e c t t h e o v e r a l l p l a n t c a p a b i l i t y t o p r o v i d e makeup i n v e n t o r y a t high r e a c t o r pressure sinc,e t h e HPCI System i s t h e o n l y h i g h pressure system assumed t o funct,ion d u r i n g a loss o f c o o l a n t accident (LOCA).

OPERABILITY o f H P C I i s t h e r e f o r e immediately v e r i f i e d when t h e R C I C System i s inoperable.

This may be performed as an a d m i n i s t r a t i v e check, by examining l o g s o r o t h e r information, t o determine i f HPCI i s o u t o f s e r v i c e f o r maintenance o r other reasons.

It does n o t mean i t i s necessary t o perform t h e Surveillances needed t o demonstrate t h e OPERABILITY o f t h e H P C I System.

IIf t h e OPERABILITY o f t h e HPCI System cannot be v e r i f i e d immediately, however, Condition B must be immediately entered.

For c e r t a i n t r a n s i e n t s and abnormal events w i t h no LOCA, R C I C (as opposed t o H P C I ) i s t h e p r e f e r r e d source o f,~

makeup cool a n t because o f i t s re1 a t i v e l y small calpaci t y,

which allows e a s i e r c o n t r o l o f t h e RPV water l e v e l.

The'refore, a l i m i t e d time i s allowed t o r e s t o r e t h e inoperable R C I C t o OPERABLE s t a t u s.

The 14 day Completion Time i s based on a r e l i a b i l i t y study (qef. 3) t h a t evaluated the impact on ECCS a v a i l a b i l i t y,

assuming various components and subsystems were taken o u t o f service.

The r e s u l t s were used t o c a l c u l a t e the average consequences o f a LOCA as a function o f allowed outage times (AOTs).

Because o f s i m i l a r functions o f HPCI and RCIC, t h e AOTs ( L e a, Completion Times) determined f o r HPCI are a l s o applied t o RCIC.

I I

f I

I I

I 6

I I

a v a i 1 abi 1 i t y o f ECCS equipment needed t o m i t i g a t e the stem cannot be restored t o OPERABLE s t a t u s PBAPS U N I T 3 Revision No.

RCIC System B 3.5.3 BASES

~~

ACTIONS (cont i nued 1 easonable, based on operating experience, t o reach the required p l a n t conditions from f u l l power conditions i n an o r d e r l y manner and without challenging p l a n t systems, SURVEI LLANCE sBLLLu REQUIREMENTS The flow path p i p i n g has the p o t e n t i a l t o develop voids'and pockets o f entrained a i r.

Maintaining t h e pump discharge l i n e o f t h e R C I C System f u l l o f water ensures t h a t t h e system w i l l perform properly, i n j e c t i n g i t s f u l l capacity i n t o the Reactor Coolant System upon demand.

This w i l l a l s o prevent a water hammer f o l l o w i n g an i n i t i a t i o n signal.

acceptable method o f ensuring the l i n e i s f u l l i s t o vent a t the high points.

The 31 day Frequency i s based on t h e gradual nature o f void buildup i n the R C I C piping, t h e procedural control s governing system operation, and operating experience.

An.

V e r i f y i n g t h e c o r r e c t alignment f o r manual, power operated, and automatic valves i n t h e R C I C flow p a t h provides assurance t h a t the proper flow path w i l l e x i s t f o r RCIC operation.

locked, sealed, o r otherwise secured i n p o s i t i o n since these valves were v e r i f i e d t o be i n t h e c o r r e c t p o s i t i o n p r i o r t o locking, sealing, o r securing.

A valve t h a t receives an i n i t i a t i o n signal i s allowed t o be i n a nonaccident p o s i t i o n provided t h e valve w i l l automatically r e p o s i t i o n i n t h e proper stroke time.

This SR does not r e q u i r e any t e s t i n g o r valve ~ a n i p u l a t i o n ; rather, i t involves v e r i f i c a t i o n t h a t those valves capable o f p o t e n t i a l l y being mispositioned are i n the c o r r e c t p o s i t i o n.

t h a t cannot be inadvertently misaligned, such as cheek valves.

For the R C I C System, t h i s SR also includes t h e steam f l o w path f o r t h e t u r b i n e and the f l o w c o n t r o l l e r posi t i on.

This SR does not apply t o valves t h a t are This SR does not apply t o valves PBAPS UNIT 3 B 3.5-27 Revision No,

RCIC System B 3.5.3 BASES (continued)

REFERENCES

1.

UFSAR, Section 1.5.

2.

UFSAR, Section 4.7.

3.

Me~orandum from R.L. Baer (NRC) to V. Stello, Jr.

(NRC), "Recommended Interim Revisions to LCOs for ECCS Components, " December 1, 1975.

PBAPS UNIT 3 B 3.5-30 Revision No.

Pr i mary Cont a i nment B 3.6.1.1 BASES LCO Individual leakage rates specified for the primary containment air lock are addressed in LCO 3.6.1.2.

( con t i nued )

APPL I CAB I LITY In MOOES 1, 2, and 3, a DBA could cause a release o f radioactive material to primary containment.

and 5, the probability and consequences o f these events are reduced due to the pressure and temperature limitations o f these MOOES.

Therefore, primary contain~ent i s not required to be OPERABLE in MOOES 4 and 5 to prevent leakage o f radioactive material from primary containment.

In MODES 4 ACT IONS A.1 In the event primary containment is inoperable, primary containment must be restored' to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

time to correct the problem commensurate with the importance o f mai nt a i ni ng primary con t a i nment OPERA61 L ITY during MOOES 1, 2, and 3.

This time period a!so ensures that the probability o f an accident (requiring primary containment OPE~BILITY) occurring during periods where primary containment i s inoperable is mini The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provides a period o f SURVE I LLANC E SR 3.6.1.1.1 REQU I REMENTS Maintaining the primary containment OPERABLE requires compliance with the visual examinations and leakage rate test requirements o f the Primary Containment Leakage Rate Testing Program. Failure to meet air lock leakage testing (SR 3.6.1.2.1),

or main steam isolation PBAPS UNIT 3 8 3.6-3 Revision No.

Primary Containment B 3.6.1.1 BASES (continued)

I REFERENCES

1.

2.

3.

4.

5.

6.

7.

UFSAR, Section 14.9.

Letter G94-PEPR-183, Peach Bottom Improved Technical Spec i f i cat i on Project Increased Drywell and Suppression Chamber Pressure Analytical Limits, from G.V. Kumar (GE) to A.A. Winter (PECO), August 23, 1994.

10 CFR 50, Appendix 3, Option B.

Safety Evaluation by the Office of Nuclear Reactor pporting Amendment Nos. 127 and 130 to Facility Operating License Nos. DPR-44 and DPR-56, dated February 18, 1988.

NEI 94-01, Revision 0, "Industry Guideline f o r Implem~nting Performance-Based Option of 10 CFR Part 50, Appendix 3."

ANSI/ANS-56.8-1994, "Containment System Leakage Testing Requirements."

Peach Bottom Atomic Power Station Evaluation for Extended Final Feedwater Reduction, NEDC-32707P, Supplement 1, Revision 0, May, 1998.

PBAPS UNIT 3 B 3.6-5 Revision No.

Reactor Bui lding-to-Suppression Chamber Vacuum Breakers B 3.6.1.5 BASES ACTIONS A. 1 (cont i nued)

"Suppression Chamber-to-Dr~ell Vacuum Breakers." The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the redundant capability afforded by the remaining breakers, the fact that the OPERABLE breaker in each o f the lines is closed, and the low probability of an event occurring that would require the vacuum breakers to be OPERABLE during this period.

With one or more lines with two vacuum breakers not closed, primary containment integrity is not maintained.

one open vacuum breaker must be closed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , This Completion Time is consistent with the ACTIONS of LCO 3.6.1.1, "Primary Containment," which requires that primary containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Therefore, With one line with one or more vacuum breakers inoperable for opening, the leak tight primary containment boundary is intact. The ability to mitigate an event that causes a containment depressurization is threatened if one or more vacuum breakers in at least one vacuum breaker penetration are not OPERABLE. Therefore, the inoperable vacuum breaker must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This is consistent with the Completion Time for Condition A and the fact that the leak tight primary containment boundary is being maintained.

With two lines with one or more vacuum breakers inoperable for opening, the primary containment boundary is intact.

However, in the event o f a containment depressurization, the function o f the vacuum breakers is lost. Therefore, all vacuum breakers in one line must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This Completion Time is consistent with the ACTIONS of LCO 3.6.1.1, which requires that primary containment be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

(continued)

PBAPS UNIT 3 B 3.6-38 Revision No.

Reactor Building-to~Suppression Chamber Vacuum Breakers B 3.6.1.5 BASES If any Required Action and associated Com be met, the plant must be brought to a MODE in which the LCO does not apply, To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

The allowed Completion Times are SURVEILLAN~E SR 3,6.1.5,1 REQUIRE~E~TS Verifying that the level in the CAD liquid nitrogen tank is 2 16 inches water column will ensure at least 7 days o f post-LOCA SGIG System operation.

liquid nitrogen allows sufficient time after an accident to replenish the nitrogen supply in order to maintain the design function of the reactor building-to-suppression vacuum breakers. The level is verified every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to ensure that the system is capable of performing its intended isolation function when required, The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on operating experience, which has shown to be an acceptable period to verify liquid nitrogen supply. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency also signifies the importance o f the SGIG System for maintaining the design function of the reactor building-to-suppression chamber vacuum breakers.

This minimum volume o f SR 3.6.1.5.2 This SR ensures that the pressure in the SGIG System header is 2 80 psig, This ensures that the post-LOCA nitrogen pressure provided to the valve operators and valve seals that is adequate for the SGIG to perform its design function, The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency was developed considering the importance o f the S616 System for maintaining the design function of the reactor building-to-suppression-chamber vacuum breakers, The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is also considered to be adequate to ensure timely detection o f any breach in the SGIG System which would render the system incapable o f performing its function.

(continued)

PBAPS UNIT 3 B 3.6-39 Revision No.

Reactor Building-to-Suppression Chamber Vacuum Breakers B 3.6.1.5 BASES SURVEILLA~CE SR 3.6.1.5.5 R E Q U I R ~ M E ~ T S (continued)

Each vacuum breaker must be cycled to ensure that it opens properly to perform its design function and returns to its fully closed position. This ensures that the safety analysis assumptions are valid.

this SR was developed based upon Inservice Testing Program requirements to perform valve testing at least once every 92 days.

The 92 day Frequency o f SR 3.6.1.5.6 Demonstration of air operated vacuum breaker opening setpoint is necessary to ensure that the safety analysis assumption regarding vacuum breaker full open differential pressure of s 0.75 psid is valid.

based on requirements associated with the instruments that monitor differential pressure between the reactor building and suppression chamber and that this Surveillance can be performed while the plant is operating.

18 month Frequency has been shown to be acceptable, based on operating experience. Operating experience has shown that these components usually pass the surveillance when performed at an 18 month frequency, and is further justified because o f other surveillances performed at shorter Frequencies that convey the proper functioning status of each vacuum breaker.

The 18 month Frequency is For this unit, the SR 3.6.1.5.7 Thi*s SR ensures that in case the non-safety grade instrument air system is unavailable, the SGIG System will perform its design function to supply nitrogen gas at the required pressure for valve operators and valve seals supported by the SGIG System. The 24 month Frequency was developed considering it is prudent that this Surveillance be performed only during a plant outage.

has shown that these components will usually pass this Surveillance when performed at the 24 month Frequency.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

Operating experience REFERENCES PBAPS UNIT 3 B 3.6-41 Revision No.

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.6 BASES

- - _ _ ~

ACTIONS A. 1 (continued) because a single failure in one of the remaining vacuum breakers could result in an excessive suppression chamber-to-drywell differential pressure during a DBA.

Therefore, with one of the nine required vacuum breakers inoperable, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to restore the inoperable vacuum breaker to OPERABLE status so that plant conditions are consistent with those assumed for the design basis analysis.

72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time i s considered acceptable due to the low probability o f an event in which the remaining vacuum breaker capability would not be adequate.

The An open vacuum breaker allows communication between the drywell and suppression chamber airspace, and, as a result, there is the potential for suppression chamber overpressurization due to this bypass leakage if a LOCA were to occur.

closed. A short time is allowed to close the vacuum breaker due to the low probability of an event that would pressurize primary containment.

is not reliable, an alternate method o f verifying that the breakers are considered closed, even if the "not fully seated" indication is shown, if a leak test confirms that the bypass area between the drywell and suppression chamber is less than or equivalent to a one-inch diameter hole (Ref, 1).

considered adequate to perform this test. If the leak test fails, not only must the Actions be taken (close the open vacuum breaker within 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months ) but a1 so the appropriate Condition and Required Actions of LCO 3.6.1.1, Primary Therefore, the open vacuum breaker must be If vacuum breaker position indication s are closed must be performed within suppression chamber-to-drywell vacuum The required 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months Completion Time is nt, must be entered, If the upcression cha~ber-to~drywell vacuum breaker cannot be closed within the required Compl brought to a HODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least (cont i nued 1 B 3-6-45 Revision No.

PBAPS UNIT 3

Suppression ~ba~ber-to~Drywel1 Vacuum Breakers B 3.6.1.6 BASES ACTIONS (cont i nued)

MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and t o MODE 4 w i t h i n 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , The allowed Completion Times are reasonable, based on operating experience, t o reach the required plant conditions from full power conditions i n an orderly manner and without chal 1 enging pl ant systems.

SURVEILLAN~E SR 3-6.1.6.1

~EQUIREMENTS Each vacuum breaker is verified closed t o ensure t h a t this potential large bypass leakage path is not present. This Surveil 1 ance is performed by observing the vacuum breaker position indication or by performing a leak test t h a t confirms t h a t the bypass area between the drywell and suppression chamber is less than or equivalent t o a one-inch diameter hole, If the bypass test fails, not only must the vacuum breaker(s) be considered open and the appropriate Conditions and Required Actions o f this LCO be entered, but also the appropriate Condition and Required Action of LCO 3.6.1.1 must be entered, engineering judgment, is considered adequate i n view o f other indications o f vacuum breaker status available t o operations personnel, and has been shown t o be acceptable through operating experience.

A Note is added t o this SR which allows suppression chamber-to-drywell vacuum breakers opened i n conjunction w i t h the performance o f a Surveillance t o not be considered as f a i l i n g this SR.

are control 1 ed by p7 ant procedures and do not represent inoperable vacuum breakers.

The 14 day Frequency is based on These periods o f opening vacuum breakers SR 3-6.1.6.2 Each required vacuum breaker must be cycled t o ensure that i t opens adequately t o perform its design function and returns t o the fully closed position.

This ensures that the safety analysis assumptions are valid.

The 31 day Frequency ofAhis SR was developed, based on Inservice Testing Program requirements t o perfom valve testing a t least once every 92 days.

A 31 day Frequency was chosen t o provide additional assurance t h a t the vacuum breakers are OPERABLE, since they are located i n a harsh environment (the suppression chamber airspace).

(con t i nued 1 PBAPS UNIT 3 B 3-6-46 Revision No.

I

Suppression Chamber-to-Drywell Vacuum Breakers B 3.6.1.6 BASES SURVEILLA~CE SR 3.6.1.6.3 RE~UIREME~TS

( c o n t i n u e d )

V e r i f i c a t i o n o f t h e vacuum b r e a k e r s e t p o i n t f o r f u l l opening i s necessary t o ensure t h a t t h e s a f e t y a n a l y s i s assumption r e g a r d i n g vacuum b r e a k e r f u l l open d i f f e r e n t i a l p r e s s u r e o f 0.5 p s i d i s v a l i d.

The 24 month Frequency i s based on t h e need t o p e r f o r m t h i s S u r v e i l l a n c e under t h e c o n d i t i o n s t h a t a p p l y d u r i n g a p l a n t outage and t h e p o t e n t i a l f o r an unplanned t r a n s i e n t i f t h e Survei 1 l a n c e were performed w i t h t h e r e a c t o r a t power.

For t h i s f a c i l i t y, t h e 24 month Frequency has been shown t o be a c c e p t a b l e, based on o p e r a t i n g experience, and i s f u r t h e r j u s t i f i e d because o f o t h e r s u r v e i l l a n c e s performed a t s h o r t e r Frequencies t h a t convey t h e p r o p e r f u n c t i o n i n g s t a t u s o f each vacuum b r e a k e r.

REFERENCES

1.

S a f e t y E v a l u a t i o n by t h e O f f i c e o f Nuclear Reactor R e g u l a t i o n S u p p o r t i n g Amendment Nos. 127 and 130 t o F a c i l i t y O p e r a t i n g L i c e n s e Nos. DPR-44 and DPR-56, dated February 18, 1988.

I

2.

ME-0161, Det. A c t u a l ## Wetwell t o D r y w e l l Vacuum Breakers Reqd PBAPS U N I T 3 B 3.6-47 R e v i s i o n No.

RHR Suppression Pool Cool ing B 3.6.2.3 BASES ACT IONS A. 1 (continued) overall re1 iabil i ty is reduced because a single failure in the OPERABLE subsystem could result in reduced primary contai nment cool i ng capabi 1 i ty. The 7 day Compl et i on Time is acceptable in light of the redundant RHR suppression pool cool ing capabil ities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.

I With two RHR suppression pool cooling subsystems inoperable, one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In this condition, there is a substantial loss of the primary containment pressure and temperature mi tigation function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is based on this loss of function and is considered acceptable due to the low probability o f a DBA and because alternative methods to heat from primary containment are avai 1 able.

To achieve this status, the plant must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to HOD 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The a1 1 owed Compl et ion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without chal 1 engi ng pl ant systems.

SURVEILLANCE SR 3.6.2.3.1 REQUIREMENTS Verifying the correct a1 ignment for manual, power operated, and automatic valves in the RHR suppression pool cooling mode flow path provides assurance that the proper flow path exists for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve i s also allowed to be in the nonaccident position provided it can be aligned to the accident position within

[continued)

PBAPS UNIT 3 B 3.6-58 Revision No.

RHR Suppression Pool Cooling 6 3.6.2.3 BASES SURVE I L LANC E SR 3.6.2.3.1 (continued)

R E Q ~ ~ R E ~ E N T S the time-assumed in the accident analysis.

acceptable since the RHR suppression pool cooling mode is manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being nispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

This is The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability o f an event requiring initiation o f the system is low, and the subsystem is a manually initiated system. This Frequency has been shown to be acceptable based on operating experience.

SR 3.6.2.3.2 Verifying that each required RHR pump develops a flow rate 2 10,000 gpm while operating in the suppression pool cooling mode with flow through the associated heat exchanger ensures that pump performance has not degraded during the cycle.

Flow is a normal test o f centrifugal pu required by ASME Code,Section XI (Ref, confirms one point on the pump design c are indicative o f overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Inservi ce Test i ng Program,

1.

UFSAR, Section 14.6.3.

. ASME, Boiler and Pressure Vessel Code,Section XI.

PBAPS UNIT 3 B 3.6-59 Revision No.

RHR Suppression Pool Spray B 3.6.2.4 BASES (continued)

ACTIONS A, 1 With one RHR suppression pool spray subsystem inoperable, the inoperable subsystem must be restored to O P E ~ B L E status within 7 days. In this Condition, the remaining OPERABLE RHR suppression pool spray subsystem is adequate to perform the primary containment bypass leakage mitigation function..

However, the overall re1 i abi 1 ity is reduced because a sing1 e failure in the OPERABLE subsystem could result in reduced primary containment bypass mitigation capability. The 7 day Completion Time was chosen in light of the redundant RWR suppression pool spray capabilities afforded 'by the OPERABLE subsystem and the low probability o f a DBA occurring during this period.

With both RHR suppression pool spray subsystems inoperable, at least one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .. In this Condition, there is a substantial loss of the primary containment bypass leakage mitigation

function, o f function and is considered acceptable due to the low probability of a DBA and because alternative methods to remove heat from primary containment are available, The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is based on this loss If the inoperable RHR suppression pool spray subsystem E status within the associated s t be brought to a MODE in To achieve this statu east MODE 3 within 12 h e allowed Completion Time ating experience, to reach from full power conditions out challenging plant systems.

SURVEILLANCE SR 3.6.2.4.1 REQU I RE~ENTS Verifying the correct a1 ignment for manual power operated, and automatic valves in the RHR suppression pool spray mode flow path provides assurance that the proper flow paths will PBAPS UNIT 3 6 3.6-62 Revision No.

RHR Suppression Pool Spray B 3.6.2.4 BASES SURVEILLANCE SR 3.6.2.4.1 (continued)

RE~UIRE~ENTS exist for system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis.

acceptable since the RHR suppression pool cooling mode is manually initiated. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

This is The Frequency of 31 days is justified because the valves are operated under procedural control, improper valve position would affect only a single subsystem, the probability of an event requiring initiation o f the system is low, and the subsystem is a manually initiated system.

has been shown to be acceptable based on operating experi ence.

This Frequency SR 3.6.2.4.2 This Surveillance i s performed every 10 years to verify that the spray nozzles are not obstructed and that f l o w will be provided when required. The 10 year Frequency is adequate to detect degradation in performance due to the passive nozzle design and its normally dry state and has been shown to be acceptable through operating experience.

REFERENCES

1.

UFSAR, Sections 5.2 and 14.6.3.

PBAPS UNIT 3 B 3.6-63 Revision No.

Secondary Contain~ent B 3.6.4.1 BASES ACTIONS (continued)

If secondary containment cannot be restored to OPERABLE required plant conditions from orderly manner and without C.1. C.2, and C.3 Movement of irradiated fuel assemblies in the secondary containment, CORE ALTERATIONS, and OPDRVs can be postulated to cause fission product release to the secondary containment.

the only barrier to release o f fission products to the envi ronment.

fuel assembl ies must be immediately suspended if the secondary containment is inoperable.

In such cases, the secondary containment is CORE ALTERATIONS and movement o f i rradi ated Suspension of these activities shall not preclude co~p7~ting an action that involves movi tion. Also, action must imediate]y i end OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended..

PBAPS UNIT 3 Required Action C.1 has been modified by a Note stating that LCO 3.0.3 i s not applicable.

assemblies while in WOE 4 or 5, LCO 3.0.3 would not specify any action-If moving irradiated fue7 assemblies while in MODE 1, 2, or 3, the fuel ~ o v e ~ n t is independent of reactor operations. Therefore, in either case, inability to suspend movement o f irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

If moving irradiated fuel 8 3.6-75 (continued)

Revision No.

Secondary Containment B 3.6.4.1 BASES

~~

SURV~~LLANCE SR 3.6.4.1.3 and SR 3.6.4.1.4

( c o n t i n u e d )

REQU I REMENTS seconds u s i n g one SGT subsystem.

t h a t t h e p r e s s u r e i n t h e secondary containment can be maintained 2 0.25 inches o f vacuum water gauge f o r 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months u s i n g one SGT subsystem a t a f l o w r a t e I; 10,500 cfm. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months t e s t p e r i o d a l l o w s secondary containment t o be i n thermal e q u i l i b r i u m a t steady s t a t e c o n d i t i o n s.

The p r i m a r y purpose o f these SRs i s t o ensure secondary containment boundary i n t e g r i t y.

The secondary purpose o f these SRs i s t o ensure t h a t t h e SGT subsystem b e i n g t e s t e d f u n c t i o n s as designed.

There i s a Separate LCO w i t h S u r v e i l l a n c e Requirements which serves t h e p r i m a r y purpose o f ensuring OPERABLITY o f t h e SGT System.

These SRs need n o t be performed w i t h each SGT subsystem.

f o r these S u r v e i l l a n c e s i s staggered t o ensure t h a t i n a d d i t i o n t o t h e requirements o f LCO 3.6.4.3, e i t h e r SGT subsystem w i l l p e r f o r m t h i s t e s t.

The i n o p e r a b i l i t y o f t h e SGT System does n o t n e c e s s a r i l y c o n s t i t u t e a f a i l u r e o f these S u r v e i l l a n c e s r e l a t i v e t o t h e secondary containment OPERABILITY. Operating experience has shown t h e secondary containment boundary u s u a l l y passes these S u r v e i l l a n c e s when performed a t t h e 24 month Frequency.

Therefore, t h e Frequency was concluded t o be acceptable f r o m a r e l i a b i l i t y s t a n d p o i n t.

SR 3.6.4.1.4 demonstrates The SGJ subsystem used REFERENCES

1.

UFSAR, S e c t i o n 14.6.3.

2.

UFSAR, S e c t i o n 14.6.4.

PBAPS UNIT 3 B 3.6-77 Revision No.

SGT System B 3.6.4.3 BASES LCO For Unit 3, one SGT subsystem is OPERABLE when one charcoal filter train, one fan (OCV020) and associated ductwork, dampers, valves, and controls are OPERABLE.

The second SGT subsystem is OPERABLE when the other charcoal filter train, one fan (OBVOZ~) and associated ductwork, damper, valves, and controls are OPERABLE.

(continued)

APPLICABILITY In MODES 1, 2, and 3, a DBA could lead to a fission product release to primary contain~ent that leaks to secondary containment. Therefore, SGT System OPERABILITY is required during these MODES.

In MODES 4 and 5, the probability and consequences of these events are reduced due to the pressure and temperature limitations in these MODES. Therefore, maintaining the SGT System in OPERABLE status is not required in MODE 4 or 5, except for other situations under which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs), during CORE ALTERATIONS, or duri ng movement o f irradiated fuel assemblies in the secondary containment.

ACTIONS A. 1 With one SGT subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status in 7 days.

Condition, the remaining OPERABLE SGT subsystem is adequate to perform the required radioactivity release control function. However, the overall system re1 iability is reduced because a single failure in the OPERABLE subsystem could result in the radioactivity release control function not being adequately performed. The 7 day Compl~tion Time is based on consideration o f such factors as the availability o f the OPERABLE redundant SGT subsystem and the low probability o f a 5BA occurring during this period.

In this Time in MODE within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

PBAPS UNIT 3 6 3.6-87 Revision No.

SGT System 6 3.6.4.3 BASES A

(continued)

The allowed Completion Tim operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

C.1. C.2.1, C.2.2.

and C2.3 During movement of irradiated fuel assemblies, in the secondary contain~nt, during CORE ALTERATIONS, or during OPDRVs, when Required Action A. 1 cannot be completed within the required Completion Time, the OPERABLE SGT subsystem should immediately be placed in operation. This action ensures that the remaining subsystem is OPERABLE, that no failures that could prevent automatic actuation have occurred, and that any other failure would be readily detected.

An alternative to Required Action C. 1 is to immediately suspend activities that represent a potential for releasing radioactive material to the secondary containment, thus placing the plant in a condition that minimizes risk.

applicable, CORE A L T E ~ T I O N ~

and movement of irradiated fuel assemblies must immediately be suspended.

to a safe posi actions must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must cont i nue unt i 1 OPDRVs are suspended.

If Suspension of ities must not The Required Actions of Condition C have been modified by a Note stating that LCO 3.0.3 i s not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent o f reactor operations. Therefore, in either case, inability to suspend movement o f irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

(continued)

PBAPS UNIT 3 B 3.6-88 Revision No.

SGT System B 3.6.4.3 BASES ACTIONS D. 1 (con t i nued )

E.1, E.2, and E.3 When two SGT subsystems are inoperable, if appl icable, CORE ALTERATIONS and movement of irradiated fuel assembl ies in secondary containment must immediately be suspended.

Suspension of these activities shall not preclude completion of movement of a component to a safe position.

applicable, actions must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product re1 ease.I Actions must cont i nue unt i 1 OPDRVs are suspended.

Also, if Required Action E.1 has been modified by a Note stating that LCO 3.0.3 is not applicable.

assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action, If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement i s independent o f reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

If moving irradiated fuel SURVEILLANCE SR 3.6.4.3.1 REQUIRE~ENTS Operating each SGT subsystem (including each filter train fan) for zr 15 minutes ensures that both subsystems are OPERABLE and that all associated controls are functioning properly, It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation with the heaters on (automatic heater cycling to maintain temperature) for 2 15 minutes every 31 days is sufficient to eliminate moisture on the adsorbers and HEPA filters since during idle periods instrument air is injected into the filter plenum to keep the filters dry, The 31 day Frequency was developed in consideration of the known reliability o f fan motors and controls and the redundancy available in the system.

(continued)

PBAPS UNIT 3 B 3-6-89 Revision No.

SGT System B 3.6.4.3 BASES SURVEILLAN~E SR 3. 6. 4. 3 2 REQUIREMENTS

( c o n t i nued )

T h i s SR v e r i f i e s t h a t t h e r e q u i r e d SGT f i l t e r t e s t i n g i s performed i n accordance w i t h t h e V e n t i 1 a t i on F i l t e r T e s t i n g Program (VFTP).

The VFTP i n c l u d e s t e s t i n g HEPA f i l t e r performance, c h a r c o a l adsorber e f f i c i e n c y, minimum system f l o w r a t e, and t h e p h y s i c a l p r o p e r t i e s o f t h e a c t i v a t e d charcoal ( g e n e r a l use and f o l l o w i n g s p e c i f i c o p e r a t i o n s ).

S p e c i f i c t e s t f r e q u e n c i e s and a d d i t i o n a l i n f o r m a t i o n a r e discussed i n d e t a i l i n t h e VFTP.

S R 3.6.4.3.3 T h i s SR v e r i f i e s t h a t each SGT subsystem s t a r t s on r e c e i p t o f an a c t u a l o r s i m u l a t e d i n i t i a t i o n s i g n a l.

W h i l e t h i s S u r v e i l l a n c e can be performed w i t h t h e r e a c t o r a t power, o p e r a t i n g e x p e r i e n c e has shown t h a t t h e s e components w i l l u s u a l l y pass t h e S u r v e i l l a n c e when performed a t t h e 24 month Frequency.

The LOGIC SYSTEM F U N ~ T I O ~ A L TEST i n LCO 3.3.6.2,

" Second a ry Con t a i nme n t I s o 1 a t i on I n s t r ume n t a t i on, " o v e r 1 a p s t h i s SR t o p r o v i d e complete t e s t i n g o f t h e s a f e t y f u n c t i o n.

T h e r e f o r e, t h e Frequency was found t o b e a c c e p t a b l e f r o m a r e 1 i a b i 1 i t y s t a n d p o i n t,

REFERENCES

1.

UFSAR, S e c t i o n 1.5.1.6.

2.

UFSAR, S e c t i o n 14.9.

I PBAPS UNIT 3 B 3. 6 - 9 0 R e v i s i o n No.

HPSW System B 3.7.1 BASES ACTIONS A. 1 (continued) could result in loss o f WPSW function. The Completion lime is based on the redundant HPSW capabilities afforded by the OPERABLE subsystem and the low probability of an event occurring requiring HPSW during this period.

The Required Action is modified by a Note indicating that the applicable Conditions of LCO 3.4.7, be entered and Required Actions taken if an inoperable HPSW subsystem results in an inoperable RHR shutdown cooling subsystem.

This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

With both HPSW subsystems inoperable, the HPSW System is not capable of performing its intended function. At least one subsystem must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time for restoring one HPSW subsystem to OPERABLE status, is based on the Completion Times provided for the RHR suppression pool cooling and spray functions.

The Required Action is modified by a Note indicating that the applicable Conditions of LCO 3.4.7, be entered and Required Actions taken if an inoperable HPSW subsystem results in an inoperable RHR shutdown cooling subsystem.

This i s an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

If the HPSW subsystems cannot be resto o OPERABLE status within the associated Completi~n Tim e unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The a1 7 owed Compl et i on Times are reasonabl e, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without chal lenging unit systems.

PBAPS UNIT 3 (cont i nued)

B 3.7-4 Revision No.

HPSW System B 3.7.1 BASES (continued)

SURVEILLA~CE SR 3.7.1.1 R E Q U I R E ~ E N ~ S Verifying the correct alignment for each manual and power operated valve i n each HPSW subsystem flow path provides assurance that the proper f l o w paths will exist for HPSW operation.

locked, sealed, or otherwise secured i n position, since these valves are verified t o be i n the correct position prior t o locking, sealing, or securing.

A valve i s also allowed t o be i n the nonaccident position, and yet considered i n the correct position, provided i t can be realigned t o its accident position.

This i s acceptable because the HPSW System is a manually initiated system.

This SR does not apply t o valves that are This SR does not require any testing or valve manipulation; rather, i t involves verification that those valves capable of being mispositioned are i n the correct position.

does not apply t o valves t h a t cannot be inadvertently misaligned, such as check valves.

This SR The 31 day Frequency is based on engineering judgment, is consistent w i t h the procedural controls governing valve operation, and ensures correct valve positions.

REFERENCES

1.

UFSAR, Section 10.7.

2.

UFSAR, Chapter 14.

3.

NEDC-32183P, "Power Rerate Safety Analysis Report For Peach Bottom 2 & 3," May 1993.

PBAPS UNIT 3 B 3-7-5 Revision No.

ESW System and Normal Heat Sink B 3.7.2 BASES SURVEI L LANC E SR 3.7.2.4 REQUIREM~NTS (continued)

This SR verifies that the ESW System pumps will automatically start to provide cooling water to the required safety related equipment during an accident event.

demonstrated by the use o f an actual or simulated initiation signal,

This is Operating experience has shown that these components will usually pass the SR when performed at the 24 month Frequency. Therefore, this Frequency is concluded to be acceptable from a reliability standpoint.

REFERENCES 1,

UFSAR, Chapter 14.

PBAPS UNIT 3 B 3.7-10 Revision No.

MCREV System B 3.7.4 BASES ACTIONS A. 1 (cont i nued) result in reduced MCREV System capability.

Completion Time is based on the low probability of a DBA occurring during this time period, and that the remaining subsystem can provide the required capabilities.

The 7 day In MODE 1, 2, or 3, if the inoperable MCREV subsystem cannot be restored to OPERABLE status within the associated e, the unit must be placed in a MODE that To achieve this status, ast MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months The a7 1 owed Compl et i on on operating experience, itions from full power orderly manner and without challenging unit systems.

C.1, C.2.1. C.2.2, and C.2.3 The Required Actions of Condition C are modified by a Note indicating that LCO 3.0.3 does not apply.

irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

Therefore, inability to suspend movement o f irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

If moving During movement of irradiated fuel assemblies in the secondary containment, during CORE A L T E ~ T I O ~ S,

or during OPDRVs, if the inoperable MCREV subsystem cannot be restored to OPERABLE status within the required Completion Time, the O P E ~ ~ L E MCREV subsystem may be placed in operation. This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent automatic actuation will occur, and that any active failure will be readily detected.

An alternative to Required Action C.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk.

kont inued)

PBAPS UNIT 3 B 3.7-18 Revision No.

MCREV System B 3.7.4 BASES ACTIONS C.1. C.2.1, C.2.2, and C.2.3 (continued).

If applicable, CORE ALTE~TIONS and movement of irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion o f movement of a component to a safe position.

Also, if applicable, actions must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel drain do^ and the subsequent potential for fission product release. Actions must continue until the OPDRVs are suspended.

If both MCREV subsystems are inoperable in MODE 1, 2, or 3, E. 1, E.2, and E.3 The Required Actions o f Condition E are modified by a Note indicating that LCO 3.0.3 does not apply.

irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement i s independent of reactor operations.

Therefore, inability to suspend movement o f irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

If moving During movement o f irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during OPDRVs, with two MCREV subsystems inoperable, action must be taken i~ediately to suspend activities that present a potential for releasing radioactivity that might require isolation of the control room, This places the unit in a condition that minimizes risk.

If applicable, CORE A L T E ~ T I O ~ S and movement of irradiated fuel assemblies in the secondary containment must be suspended immediately. Suspension of these activities shall not preclude completion of movement of a component to a safe position. If applicable, actions must be initiated (continued 1 PBAPS UNIT 3 B 3.7-19 Revision No.

MCREV System B 3.7.4 BASES SURVE I L LANC E REQU I REMENTS (continued)

SR 3.7.4.4 This SR v e r i f i e s the i n t e g r i t y o f the control room enclosure, and the assumed inleakage rates o f potentially contaminated a i r.

The control room p o s i t i v e pressure, with respect t o p o t e n t i a l l y contaminated adjacent areas (the turbine building), i s periodically tested t o v e r i f y proper function o f the MCREV System.

During operation, the MCREV System i s designed t o s l i g h t l y pressurize the control room

z 0.1 inches water gauge positive pressure with respect t o the turbine building t o prevent u n f i l t e r e d inleakage.

The MCREV System i s designed t o provide t h i s p o s i t i v e pressure a t a flow r a t e o f z 2700 cfm-and 3 3300 cfm t o the control room when i n operation.

Manual adjustment o f the MCREV System may be required t o establish the f l o w r a t e o f L 2700 cfm and s 3300 cfm during SR performance.

The Frequency o f 24 months on a STA~GERED TEST BASIS i s consistent with other f i l t r a t i o n systems SRs.

REFERENCES

1.

UFSAR, Section 7.19.

2.

UFSAR, Section 10.13.

3.

UFSAR, Section 12.3.4.

4.

UFSAR, Section 14.9.1.5.

PBAPS UNIT 3 B 3.7-21 Revision No.

Main Condenser Offgas 6 3.7.5 BASES LCO with this requirement (3293 MWt x 100 fli/MWt-second =

320,000, pCi/second) and i s based on the original licensed rated thermal power.

(cont i nued)

APPLICABILITY The LCO is applicable when steam is being exhausted to the main condenser and the resulting noncondensibles are being processed via the Main Condenser Offgas System. This occurs during MODE 1, and during MODES 2 and 3 with any main steam line not isolated and the SJAE in operation, and 5, steam is not being exhausted to the main condenser and the requirements are not appl i cab1 e.

In MODES 4 ACTIONS A. 1 If the offgas radioactivity rate limit is exceeded, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to restore the gross gamma activity rate to within the limit.

reasonable, based on engineering judgment, the time required to complete the Required Action, the large margins associated with permi s s i ble dose and exposure 1 imi ts, and the low probability of a Main Condenser Offgas System rupture.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is If the gross gamma activity rate is not restored to within the limits in the associated Completion Time, all main steam lines or the SJAE must be isolated, This isolates the Main Condenser Offgas System from the source o f the radioactive steam. The main steam lines are considered isolated if at least one main steam isolation valve in each main steam line is closed, and at least one main steam line drain valve in each drain line inboard of the main steam isolation valves i s closed, The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Comp~etion Time i s reasonable, based on operating experience, to perform the actions from full power conditions in an orderly manner and without challenging unit systems.

achieve this status, t MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed Completion Tim PBAPS UNIT 3 B 3.7-23 Revision No.

Main Condenser Offgas B 3.7.5 BASES A C T I O ~ S (continued).

experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

S ~ R V E I L L A N ~ E SR 3.7.5.1 REQUIREMENTS This SR, on a 31 day Frequency, requires an isotopic analysis of an offgas sample to ensure that the required limits are satisfied. The noble gases to be sampled are Xe-133, Xe-135, Xe-138, Kr-85m, Kr-87, and Kr-88. If the measured rate of radioactivity increases significantly (by 2 50% after correcting for expected increases due to changes in T

~

L POWER), an isotopic analysis is also performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the increase is noted, to ensure that the increase is not indicative of a sustained increase in the radioactivity rate. The 31 day Frequency is adequate in view of other instrumentation that continuously monitor the offgas, and is acceptable, based on operating experience.

This SR is modified by a Note indicating that the SR is not required to be performed until 31 days after any main steam line is not isolated and the SJAE i s in operation. Only in this condition can radioactive fission gases be in the Main Condenser Offgas System at significant rates, REFERENCES

1.

UFSAR, Section 9.4.5.

2.

10 CFR 100.

PBAPS UNIT 3 B 3.7-24 Revision No.

AC Sources-Operating B 3.8.1 BASES ACTIONS F. I (continued)

With two or more DGs inoperable, with an assumed loss of offsite electrical power, insufficient standby AC sources are available to power the minimum required ESF functions.

Since the offsite electrical power system is the only source of AC power for the majority of ESF equipment at this level o f degradation, the risk associated with continued operation for a very short time could be less than that associated with an immediate controlled shutdown, (The immediate shutdown could cause grid instability, which could result in a total loss o f AC power,) Since any inadvertent unit generator trip could also result in a total loss o f offsite AC power, however, the time allowed for continued operation is severely restricted.

risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.

The intent here i s to avoid the According to Regulatory Guide 1-93 (Ref. 6), with two or more DGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , assumed the unit has two DGs.

results in a total loss of onsite power, Therefore, a loss of more than two DGs, in the Peach Bottom Atomic Power Station design, results in degradation no worse than that assumed in Regulatory Guide 1.93.)

(Regulatory Guide 1-93 Thus, a loss of both DGs If the inoperable AC electrical power source(s) cannot be restored30 OPERABLE status within the associated Completion Time (Required Action and associated Completion Time o f Condition A, C, D, E, or F not met; or Required Action B.2, 2, or 8.5 and associated Completion Time not must be brought to a MODE in which th To achieve this status, the unit mu MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months e allowed Completion T tions from full power conditions in an ithout challenging plant systems, operating experience, to reac (Continued 1 PBAPS UNIT 3 B 3-8-17 Revision No,

AC Sources-Operating B 3.8.1 BASES SURVEILLAN~E SR 3.8.1.21 (continued)

REQUIRE~ENTS U n i t 2 Technical Specifications exempts performance of a Unit 2 SR (However, as stated i n the Unit 2 SR 3.8.2.1 Note, while performance of an SR is exempted, the SR still must be met).

REFERENCES

1.

2.

3.

4.

60

7.

8.

9.

10.

UFSAR, Sections 1.5 and 8.4.2.

UFSAR, Sections 8.3 and 8.4.

Regulatory Guide 1.9, July 1993.

UFSAR, Chapter 14.

Generic Letter 84-15.

Regulatory Guide 1.93, December 1974.

UFSAR, Section 1.5.1.

Regulatory Guide 1.108, August 1977.

Regulatory Guide 1.137, October 1979.

UFSAR, Section 8.5, PBAPS UNIT 3 B 3.8-39 Revision No.

DC Sources-Operating B 3.8.4 BASES ACTIONS (continued)

If the DC electrical power subsystem cannot be restored t o Condition E corresponds t o a level of degradation i n the DC electrical power subsystems that causes a required safety function t o be lost. When more than one DC source is lost, this results i n a loss o f a required function, t h u s the plant is i n a condition outside the accident analysis.

Therefore, no additional time is justified f o r continued operation.

commence a controlled shutdown.

LCO 3.0.3 must be entered immediately t o

_ ~ _ _ _ _

~

S~RVEILLAN~E REQUIRE~ENTS As Noted a t the beginning o f the SRs, SR 3.8.4.1 through SR 3.8-4.8 are applicable only t o the Unit 3 DC electrical power subsystems and SR 3.8,4.9 i s applicable only t o the U n i t 2 DC electrical power subsystems.

SR 3.8.4.1 Verifying battery terminal voltage while on float charge for the batteries helps t o ensure the effectiveness o f the charging system and the a b i l i t y o f the batteries t o perform their intended function.

Float charge is the condition i n which the charger is supplying the continuous charge required t o overcome the internal losses o f a battery (or battery cell) and maintain the battery (or a battery cell) i n a f u l l y charged state. The voltage requirements are k o n t i nued 1 PBAPS UNIT 3 B 3.8-64 Revision No.

DC Sources-Operating B 3.8.4 BASES REFERENCES

4.

Regulatory Guide 1.93, December 1974, (cont i nued) 5, IEEE Standard 450, 1987, PBAPS UNIT 3 8 3.8-71 Revision No.

BASES Distribution Systems-Operating B 3.8.7 ACTIONS D.1

(~ontinued)

This Completion Time allows for an exception to the normal "time zero" f o r beginning the allowed outage time "clock."

This allowance results in establishing the "time zero" at the time LCO 3.8.7.a was initially not met, instead o f at the time Condition D was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential o f failing to meet the LCO indefinitely, If the inoperable electrical power distribution subsystem orderly manner and without chal 1 enging pl ant systems.

Condition F corresponds to a level o f degradation in the electrical power distribution system that causes a required safety function to be lost. When more than one Condition is entered, and this results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation, to commence a controlled shutdown.

LCO 3.0-3 must be entered immediately SURVEILLANCE SR 3-8.7.1 REQUIRE~ENTS This Surveillance verifies that the AC and DC electrical power distribution systems are functioning properly, with the correct circuit breaker alignment (for the AC electrical power distribution system only).

The correct AC breaker a1 ignment ensures the appropriate separation and independence o f the electrical buses are maintained, and power is available to each required bus, o f indicated power availability on the AC and DC buses The verification i

(continued)

PBAPS UNIT 3 B 3.8-91 Revision No.

Di s t ri but i on Sys terns -0perat i ng B 3.8.7 BASES SURVE~LLANCE SR 3.8.7.1 (continued)

REQU 1 REMENTS ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. This may be performed by verification o f absence o f low voltage alarms. The 7 day Frequency takes into account the redundant capability o f the AC and DC electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES

1.

UFSAR, Chapter 14.

2.

Regulatory Guide 1.93, December 1974.

PBAPS UNIT 3 B 3.8-92 Revision No.

ENCLOSURE 4 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Exelon Generation Company, LLC (EGC) in this document. Any other statements in the submittal are provided for information purposes and are not considered to be regulatory commitments.

COMMITMENT TYPE COMMITMENT COMMITTED DATE ONE-TIME ACTION (Yes/No)

PROGRAMMATIC (Yes/No)

EGC will follow the guidance established in Section 11 of NUMARC 93-01, Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Nuclear Management and Resource Council, Revision 3, July 2000.

Ongoing No Yes EGC will follow the guidance established in TSTF-IG-05-02, Implementation Guidance for TSTF-423, Revision 0, Technical Specifications End States, NEDC-32988-A, September 2005.

Implement with amendment No Yes

ML061950597

Contents

Text

Subject:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

5.0 REFERENCES

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

5.0 REFERENCES

3.5.1 APPLICABILITY

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ML061950597

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Subject:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

5.0 REFERENCES

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

5.0 REFERENCES

3.5.1 APPLICABILITY

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